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V2049-19 ·7 August 2019 ·consulta-vinculante Medium impact
Tax

Mergers may qualify for special regime if carried out for valid economic reasons

The applicant asks whether their operations can qualify for the special merger regime under Corporate Income Tax. The DGT indicates that to do so, they must meet commercial and tax requirements and must not have fraud or tax advantage as their primary objective.

In 6 key points

How it affects those involved

Companies planning structural changes must ensure that mergers are driven by genuine economic purposes rather than purely tax-driven motives to benefit from tax neutrality.

Lifecycle

2019-08-07PublishedPublished 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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