Spain's DGT backs tax consolidation group for an investment company and its real estate subsidiary

FinanceInternationalFiscal ImpuestosNov 12, 2026, 7:18 AMAI summary

Spain's Directorate General of Taxation, in binding ruling V5195-26 of July 17, 2026, confirms that a company engaged in managing financial investments and strategic direction can be the parent of its wholly owned real estate subsidiary and form a tax consolidation group under Corporate Income Tax. The regime requires meeting the participation, control and agreement-maintenance requirements of articles 58 and 61 of the LIS and notifying the tax authority before the start of the fiscal year.

In 40 seconds

The DGT concludes SA can be the parent of SB as it holds 100% of its capital and a majority of voting rights.
Both are Spanish tax residents and are subject and not exempt from Corporate Income Tax.
To apply the regime in 2026, agreements must be adopted in 2025 and notified before the start of 2026.

Read the full story at Fiscal Impuestos

IASummary generated by artificial intelligence from a story by Fiscal Impuestos. It may contain errors: the original source prevails.

impuestos
consolidación fiscal
España
DGT
inmobiliario

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Spain's DGT backs tax consolidation group for an investment company and its real estate subsidiary

In 40 seconds

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