How the DGT's position has evolved
Current position
Non-profit entities not included in Law 49/2002 are partially exempt entities. Their income is exempt if it arises from their specific object or purpose and does not derive from an economic activity. An economic activity is considered to be one that involves the organization of material or human resources for the production or distribution of goods or services. In this case, both the income from the activity and the subsidies intended to finance it will be subject to tax.
The DGT's position remains constant in the distinction between income exempt due to social object and income subject to tax due to economic activity. The evolution shows greater precision in determining that the organization of material or human resources for specific services, such as player training or adoption management, constitutes a taxable economic activity. It is confirmed that subsidies lose their exemption if their purpose is to finance said economic activity.
Turning points
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Establishes that income from player training is taxable and not exempt as it involves the organization of material or human resources.
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Clarifies that the management and mediation in animal adoption constitutes an economic activity through the organization of resources for the distribution of services.
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Extends taxation to donations or fees intended to finance a specific economic activity.
Analysis based on 47 of 50 rulings with a stated position. Updated 19 September 2026.