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V2495-24 ·9 December 2024 ·consulta-vinculante Medium impact
Tax

Negative tax bases may be offset if the new partner already held at least 25% of the entity

The taxpayer asks whether negative tax bases can be offset following a change in shareholding resulting from an inheritance. The DGT determines that, since the requirement that new partners previously held less than 25% was not met, the limitation due to a change of control does not apply.

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Lifecycle

2024-12-09PublishedPublished 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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