How the DGT's position has evolved
Current position
Income is exempt if it arises from the corporate purpose and does not constitute economic activities, such as membership fees. An activity is considered an economic exploitation if it involves the organization of production means or human resources. In the case of AIE (Collective Investment Schemes), the regime is maintained as long as they carry out the activities of their corporate purpose, without it being necessary for their partners to carry out related activities.
The DGT's position remains constant in the distinction between income from the corporate purpose and economic activities. The evolution shows a coherent application of the concept of economic activity based on the organization of production means. No changes in criterion are observed, but rather a systematic application to different regimes such as non-profit entities or AIE.
Analysis based on 47 of 51 rulings with a stated position. Updated 19 September 2026.