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. Fiscal legal personality is obtained through a public deed or a private document submitted to the Administration to obtain the NIF. A commercial purpose requires activities of production, exchange, or provision of services in non-excluded sectors, such as the agricultural or professional sectors.
The DGT's position remains constant across all analyzed rulings. No changes are observed in the requirements for fiscal legal personality nor in the definition of commercial purpose for the application of Corporate Income Tax (IS).
Analysis based on 105 of 118 rulings with a stated position. Updated 19 September 2026.