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V2296-23 ·31 July 2023 ·consulta-vinculante Medium impact
Tax

Luxembourg holding entity B may be the dominant entity of a Spanish tax group if it meets Art. 58 LIS requirements

A query was raised regarding whether entity B could be the dominant entity of a tax group comprising companies D and E. The DGT ruled that entity B meets the requirements to be the dominant entity, whereas fund A and its partners do not, due to a lack of legal personality or subjection to an analogous tax.

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2023-07-31PublishedPublished 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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