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A patrimonial company asks whether it can apply the maximum 25% capitalisation reserve reduction for 2025 if its 2024 turnover did not exceed €1m. The DGT confirms this is possible if legal requirements are met and turnover remains below €1m over the 12 months prior to the tax period start.
Question posed: If, having not exceeded one million euros in net turnover in the 2024 fiscal year, would it be possible to apply the 25 percent limit in the application of the capitalization reserve in the Corporate Tax settlement for the 2025 fiscal year?
Family-owned holding companies may apply the capitalization reserve reduction if they are taxed at the rate specified in paragraphs 1 or 6 of Article 29 of the LIS and comply with the legal requirements. The maximum limit of the reduction shall be 25% of the positive taxable base if the net amount of the turnover for the 12 months preceding the start of the tax period is less than 1 million euros. The increase in equity must be maintained for 3 years and an unavailable reserve must be allocated.
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