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V1104-21 ·27 April 2021 ·consulta-vinculante Medium impact
Tax

Mergers may qualify for special tax regime if commercial requirements are met and valid economic reasons exist

A query was raised regarding whether the merger of four entities owned by the same siblings could qualify for the special Corporate Tax regime. The DGT indicates that it must comply with commercial regulations and Article 76.1 of the Corporate Tax Act, and its primary purpose must not be to obtain a tax advantage.

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2021-04-27PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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