Skip to content
BOE-A-2026-13181 ·17 June 2026 ·Resolution Low impact
Tax

Companies under third-party control: Directorate General cannot review AEAT decision on control relationship to cancel prohibitions

The Directorate General for Legal Certainty and Public Faith has ruled that the Registrar lacks the authority to review or resolve matters regarding a prior decision by the Administration (AEAT) concerning the fulfillment of legal requirements for a control relationship (Art. 170.6 LGT). In this instance, the preventive notation prohibiting the disposal of land owned by Peserlim S.L. was maintained, arising from debts owed by its partner Euroinversiones TMP 2012, S.L., as the control relationship was deemed proven (Facts I).

In 2 key points

  1. The Registrar cannot review the Administration's decision regarding the existence of a control relationship (Hechos II)
  2. The mandate must include details of the control relationship to comply with Art. 170.6 LGT (Hechos II)

Lifecycle

2026-06-17PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact