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A company based in Ceuta has requested clarification on whether it can apply the tax relief provided under Article 33 of the Corporate Tax Act when performing e-commerce intermediation services (dropshipping). The Directorate General for Taxes (DGT) has ruled that this relief is applicable, provided the company is domiciled in Ceuta and maintains the necessary material and human resources within that territory.
Question posed: For the purposes of the tax relief provided in Article 33 of Law 27/2014, of November 27, the following is of interest:
Companies tax-domiciled in Ceuta or Melilla with material and human resources in said territory may apply the tax relief provided in Article 33 of the Corporate Income Tax Act (LIS). This right is maintained regarding income obtained regardless of whether their clients are located in the territory of Ceuta or Melilla. Furthermore, the tax relief is applicable regardless of whether the income exceeds the threshold of 50,000 euros per employee (maximum 400,000 euros), provided that the requirements of the regulation are met.
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