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A requesting company asks whether it can apply the reduction provided in Article 23 of the TRLIS to income derived from the transfer of an intangible asset to another entity within its tax consolidation group. The DGT responds that it is possible, provided that the requirements of Article 23 are met and the rules for the elimination and incorporation of results under the tax consolidation regime are followed.
Question raised 1. Whether company C can apply the reduction provided for in Article 23 of the TRLIS to the income derived from the transfer of the described intangible to an entity of the same tax consolidation group, in accordance with the wording provided by Law 14/2013.
The reduction under Article 23 of the TRLIS is applicable to income from the transfer of intangibles between entities of the same tax consolidation group. The application shall occur to the extent that the incorporation of the elimination of the internal transaction occurs, pursuant to Articles 72 and 73 of the TRLIS. In the case of intangibles not recognized on the balance sheet, 80 percent of the income shall be taken for the elimination and incorporation operations.
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