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V1782-14 8 July 2014 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · residencia fiscal

Moving fiscal residence abroad loses Spanish residency and requires integration of latent capital gains

An entity asks about the tax consequences of relocating its registered office and effective management base to Luxembourg. The DGT clarifies that this results in losing Spanish fiscal residency and the obligation to integrate latent capital gains from its assets, unless the double taxation exemption conditions are met.

The question raised

Clarification is requested regarding various paragraphs of the response to the binding ruling submitted by the requesting entity, which are analyzed within the body of the response.

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