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V1770-23 ·20 June 2023 ·consulta-vinculante Medium impact
Tax

Merger of Spanish resident companies may qualify for special regime if LIS requirements are met

A company seeking advice intends to absorb eight entities within its tax group. The DGT indicates that the operation may apply the special merger regime provided it is carried out under the Structural Changes Act and its primary objective is not tax advantage.

In 6 key points

How it affects those involved

Companies undergoing restructuring within a tax group can benefit from tax neutrality under the special merger regime, provided they demonstrate valid economic reasons and comply with the Structural Changes Act.

Lifecycle

2023-06-20PublishedPublished 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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