Changes of residence, operations carried out with or by persons or entities resident in tax havens and amounts subject to withholding.Special rules

Section 1 of Article 19 of the LIS regulates the consequences of changes of residence of entities resident in Spanish territory, whether the transfer is to another Member State of the European Union or of the European Economic Area or to a third country.

As from 1 January 2021, the change of residence of an entity with a transfer of assets from Spain to the United Kingdom will generate a corporate income tax liability for the Spanish entities transferred, which may not be subject to splitting under any circumstances.