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V0039-19 ·4 January 2019 ·consulta-vinculante Medium impact
Tax

Special group of entities regime cannot be applied if the dominant entity is not established in Spain

A query was raised regarding whether two Spanish entities, both 100% owned by the same French entity, could benefit from the VAT group of entities regime. The Directorate General for Taxes (DGT) ruled that the regulations do not provide for this regime for entities whose parent company is not established within the tax territory.

In 6 key points

How it affects those involved

This ruling limits the ability of Spanish subsidiaries of foreign groups to benefit from VAT grouping, as the parent company must be established in Spain to qualify.

Lifecycle

2019-01-04PublishedPublished 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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