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A company inquired whether it could apply the reduced 15% tax rate for the 2025 financial year, given that its ENISA startup certificate expires on 23 December 2025. The DGT ruled that this is not possible because the startup status must be maintained until the final day of the tax period.
Question posed In the 2025 fiscal year, will the consulting entity be able to apply the reduced tax rate of 15% provided for in the Corporate Income Tax, considering that it holds the status of a startup according to the certificate issued by ENISA valid until December 23, 2025?
The 15% rate for startups applies in the first tax period with a positive base and in the following three, provided that said condition is maintained. Since the tax accrues on the last day of the tax period, it is that date which determines whether the requirements are met. If the startup status expires before December 31, the entity will not be able to apply the reduced rate in that fiscal year.
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