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

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

As of January 1, 2021, the change of residence of an entity with a transfer of assets from Spain to the United Kingdom will generate a tax debt in the Corporate Tax of the transferred Spanish entities, which cannot be subject to fractionation in any case.