Changes of residence, operations carried out with or by persons or entities resident in tax havens and amounts subject to withholding. Special rules
We inform you of the consequences of BREXIT on changes of residence
Article 19 of the LIS in 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 of the European Economic Area as if it were carried out to a third country.
As of January 1, 2021, the change of residence of an entity with the 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 of fractionation in no case.