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V1223-21 ·5 May 2021 ·consulta-vinculante Medium impact
Tax

A merger may qualify for the special regime if carried out for valid economic reasons and not for tax fraud

The taxpayer asks whether a merger operation may apply the special regime of the Corporate Income Tax. The DGT responds that, for this to occur, the operation must meet commercial and tax requirements and be carried out for valid economic reasons without the primary purpose being the exploitation of tax loss carryforwards.

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2021-05-05PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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