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V3502-19 ·20 December 2019 ·consulta-vinculante Medium impact
Tax

Article 23 LIS reduction cannot be applied if the contract does not specify the transfer of intangibles

A company inquired whether its databases, algorithms, and business procedures constituted intangible assets eligible for the reduction under Article 23 of the Corporate Income Tax Law (LIS). The DGT ruled that, as the service agreement does not explicitly reference the transfer of intangibles, the income cannot benefit from said reduction.

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2019-12-20PublishedPublished 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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