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V2439-22 25 November 2022 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidad de nueva creación

The 15% reduced rate does not apply if the activity was previously carried out by a shareholder with more than 50% ownership

A query was raised regarding whether a newly formed entity can apply the 15% tax rate during its initial periods of positive taxable income. The DGT indicates that this is not permitted if the activity was previously conducted by a natural person who now holds more than 50% of the entity.

The question raised

Cuestión planteada

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