Skip to content
V1855-24 ·6 August 2024 ·consulta-vinculante Medium impact
Tax

Patrimonial status determined on consolidated group balances for LIS art. 21 exemption

A tourism group transfers 100% of a Czech subsidiary holding a leased hotel to another group company operating it. The DGT confirms that positive income may be exempt under LIS art. 21 if participation and minimum taxation requirements are met. To assess whether the subsidiary is a patrimonial entity, valuation must be based on the consolidated quarterly balances of the subgroup, in line with consultation V1654-16.

In 7 key points

Lifecycle

2024-08-06PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact