New features published in INFORMA 2026
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149409 - RELATED TRANSACTIONS. INDIRECT PARTNER-SOCIETY LINKIt is not possible to understand that in letter a) of article 18.2 of the LIS “An entity and its partners or participants” indirect partners are included. Letter a) of article 18.2 of the LIS, It only considers as linked the partners or direct participants of an entity.
149410 - COMPENSATION OF NEGATIVE TAXABLE BASES. LIMITED COMPENSATION ENTITY THAT IS PART OF A GROUPIf a The entity is part of a group in accordance with Article 42 of the Commercial Code, will not be considered a newly created entity and Negative tax bases may be offset up to a limit of 70 percent of the taxable base.
149411 - TAX RATE. NEWLY CREATED COMPANY THAT IS PART OF A GROUP WITH AN ACTIVITY DIFFERENT FROM THE DOMINANT ONEThe reduced rate of 15% does not apply. to those societies that, being formally newly created, They are integrated into a group of companies, even though its corporate purpose is different from that of its parent company.
149412 - SPECIAL REGIME UTEs. Joint venture operating abroad: EXEMPTION ARTICLE 22 LISAccording to TEAC resolution no. 02501/2023, of March 25, 2026, since article 50 of the TRLIS does not expressly require, in order to apply the exemption, that the joint venture have assets abroad an organization of material and human resources to develop the activity in said territory, This requirement should not have been required for the 2014 fiscal year and earlier, but only from the 2015 fiscal year onwards.