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V4794-16 ·10 November 2016 ·consulta-vinculante Medium impact
Tax

Article 23 LIS reduction inapplicable to software licensing involving inseparable ancillary services

A company queried whether income from the perpetual licensing of AI software for biomedical research could qualify for the intangible asset transfer reduction. The DGT ruled that this is not possible because the transfer does not involve the underlying program information, but rather an element with inseparable ancillary services.

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2016-11-10PublishedPublished 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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