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V3250-23 ·19 December 2023 ·consulta-vinculante Medium impact
Tax

A permanent establishment may apply capitalisation reserve reduction at its own site

The DGT confirms that a permanent establishment can benefit from the reduction in taxable base due to capitalisation reserve, provided it has an appropriate capital structure, as the non-resident income tax regulation is applied under the general corporate tax regime.

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2023-12-19PublishedPublished 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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