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V0031-15 ·9 January 2015 ·consulta-vinculante Medium impact
Tax

Motives for a merger of a fully owned subsidiary may be economically valid

A company asks whether a merger of a fully owned subsidiary may qualify for the special merger regime under TRLIS and if its motives are economically valid. The DGT responds that if the transaction meets commercial and fiscal requirements, it may apply the special regime if the motives are rationalisation or restructuring, not merely fiscal.

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2015-01-09PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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