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V0933-15 ·25 March 2015 ·consulta-vinculante Medium impact
Tax

Fusion by absorption cannot benefit from special tax regime if primarily aimed at tax loss offset

A company asks whether a merger by absorption of a fully owned entity can qualify for the special tax regime. The DGT states that it does not apply if the transaction lacks valid economic motives and is primarily intended to offset negative taxable bases of the absorbed entity.

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2015-03-25PublishedPublished 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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