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Low Relevance: 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 · 2016–2024

Current position

Income from activities not specifically exempt by Article 7 of Law 49/2002 may be exempt from Corporate Tax (IS) if they are considered low-relevance operations, provided their turnover does not exceed 20,000 euros. They may also be exempt if they are auxiliary or complementary activities, as long as they do not exceed 20% of total income. If these limits are exceeded, the income will be taxed at the 10% rate.

The DGT's position has remained constant in all consultations analyzed since 2016. The administration systematically applies the limits of Law 49/2002 to determine the exemption for low relevance or auxiliary character. No changes are observed in the interpretation of the 20,000 euro thresholds or the 20% income limit.

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

Rulings on this topic

9

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