Skip to content
V2023-25 ·29 October 2025 ·consulta-vinculante Medium impact
Tax

Newly created entities may be taxed at 15% during the first two periods with a positive tax base, provided there is no transfer of activity from related entities or prior exercise by natural persons with a shareholding exceeding 50%

The DGT states that the reduced rate for new creation can be applied if the company has not carried out or received activity from a linked entity or if a shareholder with over 50% ownership has not been involved.

In 6 key points

How it affects those involved

Companies may qualify for the reduced tax rate on new creation if they meet specific conditions regarding linked entities and shareholder involvement.

Lifecycle

2025-10-29PublishedPublished 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