How the DGT's position has evolved
Current position
The leasing of real estate is considered an economic activity if there is at least one employee with a full-time employment contract. However, the outsourcing of professional management is admitted if the size and volume of income of the entity justify that it is more efficient than hiring own staff. Otherwise, the income is classified as income from real estate capital.
The DGT has maintained a rigid stance, requiring an employee with a full-time employment contract to qualify leasing as an economic activity. This position has been recently nuanced by allowing the outsourcing of professional management when the scale of the business justifies its efficiency compared to direct hiring.
Turning points
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Introduces the possibility of meeting the requirements of an economic activity through the outsourcing of professional management if the size and volume of income justify it as being more efficient.
Analysis based on 69 of 75 rulings with a stated position. Updated 8 September 2026.