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V1606-23 ·6 June 2023 ·consulta-vinculante Medium impact
Tax

Mergers and spin-offs may qualify for special corporate tax regime with ITPAJD exemption

A family group asks whether a three-company merger followed by a full spin-off can benefit from the special corporate tax regime. The DGT states that such arrangements may qualify for the regime's benefits and ITPAJD exemption, provided fiscal and commercial requirements are met and there is no primary objective of tax fraud or evasion.

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2023-06-06PublishedPublished 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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