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V3230-14 ·1 December 2014 ·consulta-vinculante Medium impact
Tax

ETVE regime applicable to societies with indirect holdings via instrumental entities

A consulting company asks whether it can apply the Foreign Holdings Entity (ETVE) regime and how its subsidiary structure affects this. The DGT responds that it is possible if the social object and nominal character requirements are met, even with indirect holdings or through intermediate entities.

In 6 key points

How it affects those involved

Societies with indirect participations or instrumental entities may qualify for the ETVE regime provided the social object and nominal character conditions are satisfied.

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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