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Consortium: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 9 rulings · 2014–2026

Current position

The consortium is a taxpayer for Corporate Income Tax (IS) due to its own legal personality. It is neither an Administration nor an autonomous body, and therefore does not enjoy full subjective exemption nor the tax incentives for patronage under Law 49/2002. In the field of Value Added Tax (IVA), service provisions that include the transfer of spaces and complementary services are considered a single taxable supply.

The DGT's position remains constant regarding the legal and tax nature of the consortium. Consultations repeatedly confirm its status as a taxpayer for Corporate Income Tax (IS) and its exclusion from full exemption regimes and patronage schemes. No changes in criterion are observed, but rather a uniform application of the regulations regarding its legal personality and tax obligations.

Analysis based on 9 of 9 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

9
V1190-14 29 Apr 2014

Non-profit consortium is subject to Corporation Tax and must declare its income

SG de Impuestos sobre las Personas Jurídicas
consorciopersonalidad jurídicaexención subjetivaexención parcialentidad sin ánimo de lucro TRLIS — RDLeg 4/2004 (derogado por la Ley 27/2014) art. 7TRLIS — RDLeg 4/2004 (derogado por la Ley 27/2014) art. 9.1
Affects CompanyExpat · Non-residentIndividual

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