How the DGT's position has evolved
Current position
Economic Interest Associations (AIE) may apply the special tax regime provided they effectively carry out the activities of their corporate purpose and comply with Law 12/1991. It is not required for partners to carry out activities related to the purpose of the AIE. The status of producer requires initiative, responsibility for the work, and ownership of rights. The bases for deductions are imputed to partners resident in Spain according to the proportion of their economic rights at the close of the period.
The DGT's position remains constant regarding the independence of the partners' activity from the purpose of the AIE. Throughout the rulings, the status of producer and the scope of the deduction base have been clarified, but without altering the principle of imputing bases to partners according to their economic rights.
Turning points
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Clarifies the content of the deduction base, including direct artistic and technical costs, but excluding structural expenses, insurance, or security.
Analysis based on 39 of 40 rulings with a stated position. Updated 23 September 2026.