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V2274-15 20 July 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · consolidación fiscal

The application of the LIS is mandatory if the financial year begins on April 1, 2015

It is inquired whether the commencement of a new financial year on April 1, 2015, implies the application of Law 27/2014 on Corporate Income Tax. The DGT responds in the affirmative, as the law applies to tax periods commencing on or after January 1, 2015.

The question raised

Question raised 1) Whether the commencement of a new financial year on April 1, 2015, would trigger the application of Law 27/2014, of November 27, on Corporate Income Tax.

The DGT's ruling

Law 27/2014 applies to tax periods commencing on or after January 1, 2015. If the financial year of the entities within a tax group begins on April 1, 2015, said law shall apply to them. In the event that an entity acquires the status of dominant entity, the previous tax group shall be extinguished with the effects provided for in Article 74.3 of the LIS.

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