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A French group plans a merger where entity Y will absorb its subsidiary X, resulting in Spanish entity A becoming part of Y. The DGT examines whether this transaction qualifies for fiscal neutrality and how patrimonial gains would be taxed in Spain.
Spanish taxpayers may face tax liabilities on patrimonial gains from mergers involving French real estate holdings if the absorption structure does not meet fiscal neutrality criteria.
The tax team reviews your specific situation.
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