Capitalisation reserve for asset-holding companies: the Spanish Directorate-General for Taxes confirms its application and the 25% limit
Being an asset-holding company does not prevent a company from applying the capitalisation reserve for Spanish Corporate Income Tax purposes. The Spanish Directorate-General for Taxes (DGT) confirmed this in a 2026 binding ruling concerning a company that leases commercial premises and has no employees managing those rentals. In addition, the DGT clarified an issue that









