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V0171-22 ·3 February 2022 ·consulta-vinculante Medium impact
Tax

Requirements for special tax regime of share exchange, split and merger in Corporate Tax

An entity asks whether a series of share exchanges, partial splits and absorption mergers can benefit from the Corporate Tax special regime. The DGT states that eligibility depends on meeting voting rights majority requirements, prior business activity, and the absence of purely fiscal motives.

In 6 key points

How it affects those involved

Companies considering share exchanges, partial splits or absorption mergers must verify voting rights, prior business activity and genuine economic objectives to qualify for the special Corporate Tax regime.

Lifecycle

2022-02-03PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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