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V0541-14 ·28 February 2014 ·consulta-vinculante Medium impact
Tax

Negative income from the transfer of shares in a tax consolidation group is included in the group's tax base, reduced by compensated negative tax bases

A consulting entity asks whether the loss from the transfer of shares in two companies (S3 and S4) is deductible in 2013. The DGT rules that negative income from the transfer shall be included in the group's tax base, but must be reduced by the percentage of negative tax bases of the transferred companies that have been offset within the group.

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2014-02-28PublishedPublished 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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