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V2226-25 ·19 November 2025 ·consulta-vinculante Medium impact
Tax

Reduced tax rate not applicable without effective economic activity

An entity established in 2015 asked whether it could apply the reduced tax rate for new creations in 2024 after gaining profits from the sale of a property. The DGT states that if there is no evidence of production organisation or human resources, the entity does not carry out an economic activity and is not entitled to the reduced rate.

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Lifecycle

2025-11-19PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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