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V3228-14 ·1 December 2014 ·consulta-vinculante Medium impact
Tax

Fiscal group not extinguished if subsidiary remains dominant and new entity formed

A foreign credit entity asks whether transferring a share and creating a new entity (NewCo) extinguishes its fiscal group. The DGT responds that the group does not end because the subsidiary retains its dominant status and the new entity is integrated from inception.

In 6 key points

How it affects those involved

The fiscal group remains intact when a subsidiary continues to be the dominant entity and a new entity is established from its inception.

Lifecycle

2014-12-01PublishedPublished 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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