How the DGT's position has evolved
Current position
Non-profit entities not included in Law 49/2002 are partially exempt from Corporate Tax (IS). The exemption does not cover income from economic activities, defined as the self-managed organization of production means or human resources. If the entity carries out an economic activity, its income and the fees or donations intended to finance it will be subject to the tax.
The DGT's position remains constant regarding the distinction between exempt income and economic activities. Rulings confirm that the exemption requires income to derive from the social purpose without constituting an economic exploitation. No changes in criterion are observed, but rather a repeated application of the exemption limits in Corporate Tax (IS) and VAT (IVA).
Turning points
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Specifies that catering services for educational centers do not enjoy the education exemption if they are not provided directly by the teaching center.
Analysis based on 22 of 24 rulings with a stated position. Updated 24 September 2026.