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V0895-15 ·23 March 2015 ·consulta-vinculante Medium impact
Tax

Cross-border merger may qualify for IS special regime if commercial criteria are met and no tax evasion motives are present

A Swiss and a Spanish company plan a absorption merger to enable the Spanish entity to operate in Switzerland via a branch. The DGT examines whether the transaction qualifies for the IS special regime and its implications for IRNR, ITP/AJD and VAT.

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2015-03-23PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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