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A company inquired whether it could apply the reduced tax rate for newly established entities after commencing activity in 2023. The DGT responds that this does not apply if the activity was previously carried out by a linked party and transferred to the entity.
Question posed: Whether Company A is considered a newly created company for the 2023 and 2024 fiscal years, allowing for the application of the reduced tax rate of 15% regulated in Article 29 of the Corporate Income Tax Law
To apply the reduced rate of 15%, the entity must be newly created and carry out an economic activity. An activity shall not be deemed to have commenced if it was previously carried out by linked persons or entities and transferred to the new entity. In this case, as there is a link between the company and the deceased (father of the partners) and it appears that the activity, inventory, and fixed assets have been transferred, the reduced rate is not applicable.
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