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V1775-21 ·8 June 2021 ·consulta-vinculante Medium impact
Tax

Cross-border merger does not breach capitalisation reserve requirements if the reserve is allocated to the new branch

A query was raised regarding whether a cross-border merger breaches the capitalisation reserve maintenance requirements for the 2015 and 2016 financial years. The DGT ruled that the reserve must be allocated to the new branch's endowment fund and that the increase in equity will be accounted for in said branch.

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2021-06-08PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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