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A company tax resident in Spain due to its effective management being located there has requested a ruling on whether moving its registered office to the United Kingdom triggers the application of Article 19 of the Corporate Income Tax Act. The DGT has ruled that the loss of tax residence resulting from the relocation of effective management necessitates the integration of the difference between the market value and the tax value of the company's assets.
Cuestión planteada En el caso de que la entidad X traslade su domicilio social a Reino Unido, si quedaría sujeta a la imposición por cambio de residencia del artículo 19 de la Ley del Impuesto sobre Sociedades.
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