Companies in Ceuta or Melilla may claim tax relief on dropshipping income in Corporate Tax

Companies with tax residence in Ceuta or Melilla operating through digital business models, such as dropshipping, have received key confirmation regarding their tax treatment in Corporate Tax (IS).

What the DGT has ruled

The Directorate General of Taxes (DGT) has determined that companies tax-domiciled in Ceuta or Melilla that possess material and human resources in said territories can apply the relief provided for in Article 33 of the Corporate Tax Law (LIS).

The criteria establish two fundamental points for the application of this benefit:

• Customer location: The right to the relief is maintained regarding the income obtained, regardless of whether the customers contracting the services or products are located in Ceuta or Melilla or anywhere else in the world.
• Income thresholds: The relief is applicable regardless of whether the income exceeds the threshold of 50,000 euros per employee (with a maximum of 400,000 euros), provided that the requirements demanded by current regulations are met.

What this means for you

For companies operating from these regions with intermediation models or digital services, this criterion provides legal certainty. It means that the nature of the activity (such as dropshipping) or the geographical dispersion of the customer base does not nullify the possibility of accessing the IS relief, provided that the operating structure (human and material resources) is effectively established in Ceuta or Melilla.

What should be done

It is necessary to verify that the company strictly complies with the requirements for material and human resources in the territory to support the activity. Since the application of the relief depends on compliance with the regulations of Article 33 of the LIS, each operating situation must be analyzed to ensure that the cost structure and physical presence in the region are consistent with what the Tax Administration requires.