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V5479-26 17 August 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidad de nueva creación

Reduced 15% tax rate applicable to new entities if economic activity requirements are met and they are not holding companies or part of a group

The query examines whether an entity incorporated in 2022 can apply the reduced tax rate for new companies. The DGT rules that this is possible provided the entity carries out an economic activity, is not a holding company, and is not part of a corporate group.

The question raised

Question posed: Whether the consulting entity may apply the reduced rate provided for in Article 29.1 of the LIS for newly created entities.

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