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A mainland company inquired whether it could apply the increased Canary Islands R&D+i tax credit rates to the deduction bases imputed by an Economic Interest Group (AIE) domiciled in the islands. The Directorate General for Taxes (DGT) ruled that, as the applicant has neither tax residence nor a permanent establishment in the Canary Islands, it is ineligible for these increased rates.
Question posed: Whether the inquiring entity may apply the deductions provided for in Article 35 of the Corporate Tax Law, deriving from R&D&i activities carried out exclusively in the Canary Islands and imputed by AIEs domiciled in said territory, to the increased percentages resulting from the provisions of Article 94 of Law 19/1994.
The AIE generates the right to the R&D&i tax credit and imputes it to its partners as tax credit bases. However, to apply the increased percentages of the Canary Islands, the partner must be a resident in the archipelago or have a permanent establishment there. Since the applicant does not meet this requirement of residence or establishment in the Canary Islands, it may only apply the percentages of the common regime.
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