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V1070-14 ·14 April 2014 ·consulta-vinculante Medium impact
Tax

Transfer of shares following a demerger could invalidate special tax regime if deemed non-negligible

A query was raised regarding whether the subsequent transfer of shares between partners following a proportional total demerger would affect the special Corporate Tax regime. The DGT indicates that this could be interpreted as a method to circumvent the requirements for proportional demergers or to execute a non-proportional demerger.

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2014-04-14PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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