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V2043-19 ·7 August 2019 ·consulta-vinculante Medium impact
Tax

Operation could qualify for special merger regime if commercial requirements and valid economic motives are met

A company asks whether transferring its assets to an entity holding its entire capital may qualify for the special merger regime and whether valid economic grounds exist. The DGT states that eligibility depends on compliance with commercial law and LIS requirements, and that alleged economic motives may be valid if it is proven they do not solely aim at tax advantage.

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2019-08-07PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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