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V0016-25 ·7 January 2025 ·consulta-vinculante Medium impact
Tax

Reduced tax rate not applicable if linked party previously carried out activity

A company inquired whether it could apply the reduced tax rate for newly established entities after commencing activity in 2023. The DGT responds that this does not apply if the activity was previously carried out by a linked party and transferred to the entity.

In 6 key points

Lifecycle

2025-01-07PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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