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V1273-14 13 May 2014 · SG de Impuestos sobre el Consumo Criterion in force
IVA · holding mixta

Special group of entities regime may be maintained if the parent company is a mixed holding

A parent company of a group transformed into a banking foundation and requested clarification on whether it could continue to apply the special group of entities regime. The DGT ruled that, as it performs management and administration activities, it retains its status as a trader and may continue to act as the parent company.

The question raised

Appropriateness of continuing to apply the special regime for groups of entities

The DGT's ruling

The status of entrepreneur or professional for a holding company depends on whether it is a 'pure holding' (mere holding of shares) or a 'mixed holding' (involvement in management). If the entity provides management, administration, or financial services to its subsidiaries using its business assets, it carries out an economic activity subject to VAT. In this case, the consulting entity maintains its status as an entrepreneur and may act as the dominant entity of the group.

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