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V1071-14 ·14 April 2014 ·consulta-vinculante Medium impact
Tax

Possibility of applying special merger regime in a German-UK merger

A German company's Spain branch will be absorbed by its UK resident shareholder. The DGT examines whether the transaction qualifies for the special merger regime and its impact on the Spanish branch's taxation.

In 6 key points

How it affects those involved

The transaction may allow for the special merger regime, affecting the Spanish branch's taxable bases and enabling negative taxable bases and tax deferral.

Lifecycle

2014-04-14PublishedPublished 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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