Doctrine by topic · DGT Observatory

Professional Civil Society: 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 · 2015–2026

Current position

Professional civil societies are taxed through the income attribution regime to their partners, as they lack a commercial purpose. The amounts that partners receive for their work are not income from employment nor deductible expenses for the entity, but rather advances on their share of the economic activity's income. The withholdings borne by the entity are deducted in each partner's personal tax return according to the proportion of attributed income.

The DGT's position remains constant in the distinction between commercial and professional civil societies. Throughout the rulings, it has been reaffirmed that professional societies are taxed by income attribution and that payments to partners are not salaries. No doctrinal changes are observed, but rather a repeated application of the same principles regarding the nature of income and legal personality.

Analysis based on 9 of 9 rulings with a stated position. Updated 29 September 2026.

Rulings on this topic

9
V0065-22 17 Jan 2022

A Romanian professional civil society may be a 'person' under the Convention

SG de Fiscalidad Internacional
sociedad civil profesionalconvenio de doble imposiciónresidencia fiscalentidad en atribución de rentaspersona a efectos del convenio Convenio entre España y Rumanía para evitar la doble imposiciónLGT — Ley 58/2003 General Tributaria art. 85
Affects CompanyExpat · Non-residentIndividual

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