FISCAL CONSOLIDATION

If you have several companies, the tax consolidation regime is advantageous for you.

Under this system, companies within the same group are taxed as if they were a single entity. This provides immediate benefits:

• The losses of some are offset by the profits of others in the same financial year (without having to wait for the companies that have generated losses to obtain profits in order to offset them).

• Even if there are no loss-making companies, this system is still advantageous: it practically eliminates the obligation to document related-party transactions, there is no obligation to withhold taxes on transactions between companies that form the group, etc.

A tax group must consist of a holding company and all subsidiaries in which it holds at least 75% of the capital, either directly or indirectly. While this parent-subsidiary structure may not be met initially (many business owners hold direct stakes in various companies without a holding company), it is possible to carry out restructuring operations, without incurring tax costs, to achieve this structure.

For this regime to apply in 2022, each and every company that will form part of the group must agree to it (they must do so before the end of the 2021 fiscal year). The parent company must also notify the Tax Authorities of its decision before the end of the current fiscal year.

Our professionals will analyze whether it is in your best interest to join the group scheme and will explain the advantages you will obtain by applying for it.