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A society founded in 2021 with shareholders each holding 25% asks whether it can apply the 15% tax rate. The DGT determines that, due to no prior transmission of linked activities or ownership exceeding 50%, it qualifies as a new entity, provided it is not considered a patrimonial entity.
Cuestión planteada Si la entidad consultante podría aplicar el tipo impositivo reducido del 15% previsto en el artículo 29.1 de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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