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V2670-20 ·24 August 2020 ·consulta-vinculante Medium impact
Tax

Dividends from companies not part of a tax group are not eliminated when calculating the capitalisation reserve

A company has requested a ruling on whether dividends distributed by Company A in 2015 (prior to joining a new tax group) should be included when calculating the increase in equity for the new group in 2016. The DGT has ruled that, as the company was not part of the group in 2015, these dividends are not considered internal transactions and therefore are not eliminated.

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2020-08-24PublishedPublished 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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