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V0272-15 ·23 January 2015 ·consulta-vinculante Medium impact
Tax

Application of special merger regime depends on activity requirements and absence of fraud

A taxpayer asks whether a non-cash share contribution can qualify for the special regime under the Corporate Income Tax Law, citing economic motives. The DGT states that eligibility depends on specific residency, shareholding, and economic activity requirements, and that the stated motives may be valid.

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2015-01-23PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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