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V5483-26 18 August 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidad de nueva creación

New companies may apply reduced Corporate Tax rates if they meet activity requirements and are not part of a group

A company incorporated in 2014 has requested clarification on whether it can apply the reduced tax rate for new companies. The DGT indicates that, provided it carries out an economic activity and does not fall under any regulatory exclusions, it may apply the 15% and 20% scales during periods in which its taxable base is positive.

The question raised

Question posed: To determine whether the reduced tax rate established in the Nineteenth Additional Provision of the Recast Text of the Corporate Income Tax Law (Royal Legislative Decree 4/2004, of March 5) is applicable to the consulting entity, by referral of the Twenty-Second Transitional Provision of Law 27/2014, of November 27, on Corporate Income Tax.

The DGT's ruling

Entities incorporated between 2013 and 2014 that carry out economic activities may be taxed at the reduced rate provided in the nineteenth additional provision of the TRLIS. To this end, the activity must not have been received from related parties, it must not have been previously exercised by a shareholder with more than a 50% stake, and they cannot be part of a group pursuant to Article 42 of the Commercial Code. The benefit applies to the first period with a positive taxable base and to the following period.

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