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V0591-14 ·6 March 2014 ·consulta-vinculante Medium impact
Tax

Loss of Spanish fiscal residence upon relocation of registered office and effective management base triggers integration of dormant income

An ETVE enquires whether moving its registered office and effective management base to Luxembourg would result in loss of Spanish tax residence, and whether the resulting dormant income would be exempt. The DGT confirms that residence is lost and that exemption depends on meeting the requirements of Article 21.1 of the TRLIS in all holding periods.

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2014-03-06PublishedPublished 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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