Tax Commentary 3-2015

Nuevo Reglamento del Impuesto sobre Sociedades


Royal Decree 634/2015, of July 10, 2015, approving the Corporate Income Tax Regulations (the “RIS”) was published in the Official State Gazette on July 11, 2015. What has actually been approved is a new set of regulations to adapt and update the former regulations to the new legislation in recently approved Corporate Income Tax Law 2014, of November 7, 2014 (the “LIS”).

Below is a summary of the main new features introduced by this royal decree (which entered into force on July 12, 2015 and will apply to tax periods commencing on or after January 1, 2015, with some exceptions which are indicated in the relevant sections below).

1. Asset-holding entities

2. Tax base

3. Related party transactions

4. Tax credits

5. Special regimes

  • 5.1 Obligations of Spanish and European economic interest groups and of unincorporated joint ventures
  • 5.2 Consolidated tax regime
  • 5.3 Regime applicable to the restructuring transactions

6. Management of the tax

7. Conversion of deferred tax assets into receivables claimable from the public treasury


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