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A Luxembourg company has enquired whether it retains its status as a dominant entity within a tax consolidation group following an indirect investment structure. The Directorate General for Taxes (DGT) has ruled that an entity is not considered dominant if it does not hold 75% of the share capital and the majority of voting rights, and that the loss of this status by a non-resident entity does not result in the dissolution of the tax group.
Question posed 1) Whether entity A must not be considered the dominant entity of B and the subsidiaries resident in Spain that it acquires, directly or indirectly, in the future, such that said entities shall not be integrated into the consolidated tax group of A.
Para ser dominante, la entidad debe poseer al menos el 75% del capital social y la mayoría de los derechos de voto, manteniendo ambos requisitos durante el período impositivo. La prima de emisión no computa para determinar la participación en el capital ni los derechos de voto. Si la entidad dominante es no residente y pierde su condición, el grupo fiscal no se extingue siempre que se cumplan las condiciones para que las dependientes sigan constituyendo un grupo. La nueva entidad dominante no residente debe designar a una entidad representante mediante un acuerdo comunicado por esta última a la Administración.
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