Review of the requirements for applying the reduced 15% corporate income tax rate to newly incorporated entities carrying out the same activities as their shareholders or related entities

In a recent binding ruling, the Spanish Directorate General for Taxes (Dirección General de Tributos, DGT) concluded that the mere coincidence between the activity carried out by a newly incorporated entity and that previously performed by its shareholders or other entities related to those shareholders is not, in itself, sufficient to deny the application of […]