Tax Regime Applicable to Consolidated Tax Groups in Spain: An Analysis in Light of EU Law

This article analyses the impact of the tax reform enacted by Law 27/2014 of 27 November 2014 on the definition of a tax consolidated group and the conditions for group membership, in particular the requirement to be resident in Spain. The author reviews the influence of key ECJ cases in this area on the Spanish tax reform, concluding that the reform was undertaken to ensure compliance of the tax consolidation regime with EU law.