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V1406-16 ·6 April 2016 ·consulta-vinculante Medium impact
FISCAL

Exclusion of subsidiary salaries not applicable without direct ownership

A holder of a holding company working in its subsidiaries asks whether salaries from subsidiaries can be excluded to meet the direct functions remuneration requirement. The DGT states that exclusion is not applicable due to the absence of direct ownership in the subsidiaries.

In 6 key points

How it affects those involved

Companies must consider direct ownership when calculating direct functions remuneration; exclusion of subsidiary salaries is not permitted without direct control.

Lifecycle

2016-04-06PublishedPublished 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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