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V5482-26 18 August 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidad de nueva creación

15% reduced Corporate Tax rate applicable if activity was not transferred by a 50% shareholder

A consulting entity inquired whether it could apply the reduced corporate tax rate as a newly established company. The DGT ruled that the rate may be applied provided the economic activity has not been transferred by the natural person holding 50% of the capital.

The question raised

Question posed: Whether the consulting entity can be considered a newly created entity and if the reduced rate of 15% provided for in Article 29.1 of Law 27/2014, of November 27, on Corporate Income Tax, can be applied.

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