Skip to content
Back to index
V4325-16 7 October 2016 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · consolidación fiscal

Intragroup service results should not be eliminated if they do not generate income at the consolidated level

A query was raised regarding whether results from services between companies within the same group should be eliminated when calculating the consolidated tax base. The DGT ruled that intragroup transactions that do not generate income at the group level will not be subject to elimination.

The question raised

Whether the results derived from intra-group service provisions must be subject to elimination in the calculation of the consolidated tax base.

The DGT's ruling

Eliminations are carried out in accordance with accounting regulations provided that they affect individual tax bases and with the specificities of the Corporate Income Tax Act. Reciprocal income and expenses, once homogenized, must not be subject to elimination if they do not produce any income at the consolidated level. Otherwise, a wealth shift contrary to the philosophy of tax consolidation would occur.

Book your free first meeting