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V0457-21 ·3 March 2021 ·consulta-vinculante Medium impact
Tax

Merger of two SICAVs may qualify for special Corporation Tax regime subject to legal and economic requirements

A query was raised regarding whether a merger by absorption of one SICAV by another can benefit from the special regime under the Corporation Tax Act. The Directorate General for Taxes (DGT) indicates that this is possible provided that collective investment scheme regulations are met and the transaction is driven by valid economic reasons.

In 6 key points

How it affects those involved

This ruling provides clarity for SICAVs planning restructuring operations, confirming that tax neutrality can be achieved if the merger is not solely for tax avoidance.

Lifecycle

2021-03-03PublishedPublished 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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