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A taxpayer asks whether the requirements of the special residential lease regime (such as the percentage of income or assets) can be met at the level of a tax group under consolidation. The DGT responds that these requirements must be met by each company individually, without considering the income or assets of the rest of the group.
Question raised 1. Whether, given that all entities are taxed under the special tax consolidation regime and all are engaged in residential leasing, the requirement for the application of the special residential lease regime, consisting of at least 55% of the income of the tax period or at least 55% of the asset value being capable of generating income entitled to the relief established by the regime, can be met at the tax group level, and if so, whether the eliminations and incorporations provided for in the NOFCAC should be taken into account.
The requirements for applying the residential lease regime must be met by each company within the tax group individually, without taking into account the activities, income, or assets of the other constituent entities. The tax relief shall be applied to the group's gross tax liability in the proportion that the positive income of the participating company represents relative to the total positive income of the group. Furthermore, holdings in leasing entities are not considered assets capable of generating the tax relief.
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