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V1855-20 ·9 June 2020 ·consulta-vinculante Medium impact
Tax

Reverse absorption merger may qualify for special tax regime if valid economic reasons exist and not primarily to exploit negative taxable bases

A company asks whether a reverse absorption merger can apply the special tax regime, its impact on VAT, IIVTNU, IRPF and ITP/AJD. The DGT states that the special regime applies only if the transaction has valid economic reasons and is not primarily aimed at exploiting negative taxable bases.

In 6 key points

How it affects those involved

The application of the special regime depends on whether the transaction has valid economic justification and is not primarily intended to exploit negative taxable bases.

Lifecycle

2020-06-09PublishedPublished 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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