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V2141-14 ·4 August 2014 ·consulta-vinculante Medium impact
Tax

Special merger regime applicable if valid economic reasons exist and activities are maintained

A company has enquired whether its restructuring can qualify for the special merger regime and if it is possible to offset tax loss carryforwards. The Directorate General for Taxes (DGT) responds that if the transaction is commercial in nature and supported by valid economic reasons, the regime may apply, noting that the existence of tax loss carryforwards does not prevent its application.

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2014-08-04PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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