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V1679-21 ·31 May 2021 ·consulta-vinculante Medium impact
Tax

Merger by absorption may qualify for special regime if it complies with commercial law and has valid economic reasons

A parent company of a tax group has enquired whether its proposed merger by absorption of three entities can apply the special merger regime. The DGT indicates that to qualify, it must comply with the Structural Changes Act and Article 76.1 of the Corporate Income Tax Act, and its primary purpose must not be fraud or tax advantage.

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2021-05-31PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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