How the DGT's position has evolved
Current position
For a civil society to be a taxpayer of Corporate Income Tax (IS), it must possess fiscal legal personality and a commercial purpose. Legal personality is proven through non-secret agreements expressed before the Administration via a public deed or private document for the assignment of the NIF. The commercial purpose requires performing production, exchange, or service activities in a non-excluded sector, excluding agricultural, livestock, forestry, mining, and professional activities.
The DGT's position remains constant in the definition of the requirements for legal personality and commercial purpose for civil societies. No changes are observed in the interpretation of which activities are excluded from the commercial scope. The doctrine has been uniform from 2015 to 2020.
Analysis based on 18 of 20 rulings with a stated position. Updated 25 September 2026.