How the DGT's position has evolved
Current position
Income from non-profit entities is exempt only if it arises from their specific object or purpose and does not derive from an economic activity. An economic activity is considered to be the organization of production means and human resources to distribute goods or services. If the provision involves such organization of means, the returns will be subject to tax.
The DGT's position remains constant regarding the distinction between the corporate purpose and economic activity. Throughout the rulings, it has been reiterated that the exemption requires the absence of a profit motive, free of charge services, and that members are not the primary beneficiaries. No changes in criterion are observed, but rather a systematic application of the requirements of the IVA (Value Added Tax) Law to different types of services.
Analysis based on 25 of 26 rulings with a stated position. Updated 24 September 2026.