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The consultant asks whether its Spanish subsidiaries and permanent establishments in Dutch subsidiaries should be included in its fiscal consolidation group under the new regulations. The DGT responds that they must be included if the sum of direct and indirect shareholdings reaches the required threshold.
Question posed: Whether, in accordance with the new consolidation rules, and assuming that the same shareholdings described are maintained as of the closing date of the 2015 financial year, the consolidation perimeter of your tax group will be altered with respect to the one in force for the 2014 financial year, and in particular whether the Spanish subsidiaries and permanent establishments of Dutch subsidiaries of the aforementioned Group must be integrated into it.
To calculate the total participation in an entity controlled directly and indirectly, the direct and indirect participation percentages must be summed. If this sum reaches at least 75% of the share capital (or 70% if listed on a regulated market), the Spanish subsidiaries and the permanent establishments of non-resident entities are considered dependent entities of the tax group.
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