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The applicant asks about the requirements for a newly established company to benefit from the 15% Corporation Tax rate. The DGT clarifies that the company must carry out an economic activity, must not be a holding company, and must not have received a prior business activity from related parties.
Question raised: What are the requirements to be taxed at the reduced rate of 15% in Corporate Income Tax during the first and second fiscal years in which the taxable base is positive.
Las entidades de nueva creación tributan al 15% en el primer y segundo ejercicio con base imponible positiva si realizan actividades económicas. No se considera actividad económica si la misma fue realizada previamente por partes vinculadas o por una persona física con más del 50% de participación. La promoción inmobiliaria constituye actividad económica si existe ordenación por cuenta propia de medios de producción. No se considera inicio de actividad las actuaciones preparatorias como proyectos o licencias.
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