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Los grupos de sociedades en el derecho tributario


  • Miguel Ángel Romeo Ibáñez

    (Bufete Cuatrecasas)

  • Juan Ignacio Garicano del Hoyo

    (Bufete Cuatrecasas)


The present paper pretends to approach the concept of a group of companies in a tax field, paying special attention to the meanings given by the tax legislator in every of the main taxes. This way, the references to the concept of group of companies in the Corporate Income Tax are constant, given the narrow relationship of this tax with the accountancy legislation, because the assessment of the tax base is made after the accountancy outcome. Precisely, there are two fields of Corporate Income Tax where the concept of group of companies takes special significance. On the one hand, the special regime of tax consolidation and, on the other hand, the Law 36/2006, 29th November, on Preventive Measures against Tax Fraud. At the same time, on Value Added Tax, it must be highlighted the introduction of a new regime of groups and must also be mentioned that the concept of group of companies is relevant in terms of Property Transfer Tax on chargable transfers and Legal Documentation Tax.

Suggested Citation

  • Miguel Ángel Romeo Ibáñez & Juan Ignacio Garicano del Hoyo, 2008. "Los grupos de sociedades en el derecho tributario," EKONOMIAZ. Revista vasca de Economía, Gobierno Vasco / Eusko Jaurlaritza / Basque Government, vol. 68(02), pages 56-83.
  • Handle: RePEc:ekz:ekonoz:2008204

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    tie parts; tie operations; sanctioning system;

    JEL classification:

    • K34 - Law and Economics - - Other Substantive Areas of Law - - - Tax Law
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • K22 - Law and Economics - - Regulation and Business Law - - - Business and Securities Law


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