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Coordination Group: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 8 rulings · 2015–2026

Current position

Companies that form part of a coordination group according to the PGC do not constitute a group of companies under Article 42 of the Commercial Code. In Corporate Income Tax (IS), the forgiveness of debts between these entities is recorded as a distribution of reserves and a contribution of equity, without generating tax income or expenses. For Personal Income Tax (IRPF), these operations have no effect on the partners as they are external to the operation.

The DGT's position remains constant in the distinction between coordination groups and groups under Article 42 of the Commercial Code. Initial rulings established that economic activity is determined individually within these groups. More recent rulings confirm the accounting and tax treatment of debt forgiveness between them, maintaining the independence of the entities.

Turning points

  1. V2620-16

    Establishes that companies in a coordination group are not a group of companies under Article 42 of the Commercial Code, therefore economic activity is determined individually.

  2. V1849-24

    Defines the tax treatment of the forgiveness of debts between companies in a coordination group, indicating that it does not generate income or expenses in Corporate Income Tax (IS).

Analysis based on 8 of 8 rulings with a stated position. Updated 20 October 2026.

Rulings on this topic

8

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