No. It can be very useful in many cases, but it must be justified based on structure, activity, shareholders, reinvestment strategy, and real business objectives. Its suitability is usually assessed in light of regimes such as Article 21 of the Spanish Corporate Income Tax Law and the overall corporate structure.
The Spanish Tax Agency (AEAT) highlights, among others, the existence of a real economic activity, the absence of mere asset holding as the main activity, a minimum ownership of 5% individually or 20% jointly with the family group, and the performance of management functions with relevant remuneration.
Sí. La ATC publica una reducción del 95% en la base imponible por adquisición mortis causa de bienes y derechos afectos a actividad económica, bajo los requisitos legales aplicables.
No. It is also relevant for SMEs, family groups, and business owners who want to grow in an organised way, protect profits, and avoid mistakes that can become significantly more costly later on.