Regímenes especiales en la nueva Ley y Reglamento del Impuesto sobre Sociedades

Abstract

For the purposes of a correct tax year-end 2015, discussed the innovations introduced in some of the special tax regimes for the new corporate tax law -IS- (art. 42 to art. 117 of Title VII of this work in the LIS), Law 27/2014, of 27 November -BOE no. 288 of 28 November 2014, in force in the tax period in question since 1 January.

Specifically, the amendments to be operated by the LIS present in force in the taxation of partially exempt entities are analyzed; the special scheme for small companies (with analysis of the new reserve leveling tax bases); the entities dedicated to rental housing; the tax consolidation; the special arrangements for restructuring operations; the international fiscal transparency; The institutions’ holdings of foreign securities (ETVE); and finally, the reforms carried out in the special tax regime for listed companies in the real estate investment market.

Likewise, the rules of application of certain special schemes contained in the arts are studied. 46 to 56 of Title III of Royal Decree 634/2015, of July 10, approving the Corporation Tax Regulation (RIS) is approved. With the publication of the new RIS (BOE no. 188 of July 11) has been completed that tax reform, arguably the most important of corporate taxation between existing in our tax system.