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V0483-25 ·25 March 2025 ·consulta-vinculante Low impact
Tax

Total split of a dominant entity extinguishes the fiscal group and applies extinction rules under article 74.1 LIS

A parent company, acting as a dominant entity in a fiscal group, carries out a total split to establish two new companies. The question arises whether this allows applying group integration rules (article 74.3 LIS) or whether the group extinction regime (article 74.1 LIS) applies.

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2025-03-25PublishedPublished 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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