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V2034-19 ·6 August 2019 ·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 query was raised regarding whether the merger of two companies can apply the special Corporate Tax regime and if valid economic reasons exist. The DGT indicates that to apply this regime, the operation must be carried out under the Structural Changes Law and comply with Article 76.1 of the Corporate Tax Act, and must not have the primary purpose of tax fraud or evasion.

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2019-08-06PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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