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V1884-24 ·8 August 2024 ·consulta-vinculante Medium impact
Tax

Holding companies may avoid being classified as patrimonial entities if they possess the means to manage their shareholdings

A query was raised regarding whether two new holding companies (NEWCO 1 and 2) would be classified as patrimonial entities for Corporate Income Tax purposes. The DGT indicates that, as they do not hold majority control over the investee companies, their classification depends on the average of their quarterly balance sheets and the existence of resources to manage their shareholder rights.

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2024-08-08PublishedPublished 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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