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The consultant asks whether a reduction in shareholding in a group company without loss of commercial control would require the incorporation of eliminated income. The DGT responds that if the shareholding reduction causes the entity to cease being dependent (fall below 75%), the eliminated results must be incorporated under Article 65 of the LIS.
Question raised 1. Regarding the income eliminated due to the intra-group transfer of companies S14 and S4 in the 2011 (S14 and S4) and 2012 (S14) fiscal years, whether a disposal or dilution of the percentage of participation in company C by the group will not entail the incorporation of said income insofar as no loss of control of said company (exit from the commercial consolidation) occurs in accordance with articles 39.2 and 29.1 of the Standards for the Preparation of Consolidated Annual Accounts.
The eliminated results in a tax group shall be incorporated into the tax base when the Standards for the Preparation of Consolidated Annual Accounts so establish. Specifically, if an entity ceases to be a subsidiary and is excluded from the tax group, its eliminated results shall be incorporated into its individual tax base in the period in which the exclusion occurs. For eliminations carried out in periods prior to 2015, Article 21 of the LIS shall apply without the exemption restrictions of section 4.a.2.
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