Doctrine by topic · DGT Observatory

Internal Transactions: 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 · 2014–2017

Current position

The tax base of the tax group is determined by summing the individual tax bases of the constituent entities and applying the corresponding eliminations. The elimination of profits from internal transactions must be carried out in accordance with accounting regulations and the LIS (Corporate Income Tax Law). Transactions that do not occur between group entities, such as the sale of shares from the parent company to a third party, are not eliminated.

The DGT's position remains constant in the application of tax consolidation rules for the elimination of profits from internal transactions. Rulings confirm that the determination of the tax base requires summing individual bases and applying the elimination of intra-group items according to the regulations. No changes in criterion are observed, but rather the systematic application of the rule to different scenarios.

Analysis based on 7 of 8 rulings with a stated position. Updated 1 October 2026.

Rulings on this topic

8

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