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V2435-17 ·2 October 2017 ·consulta-vinculante Medium impact
FISCAL

Economic rationale allows special merger regime in Spain

A Luxembourg-based company asks whether the merger of one of its Spanish subsidiaries can benefit from the special merger and division regime. The DGT confirms it is possible if the transaction meets commercial requirements and has valid economic purposes, including the substitution of negative taxable bases.

In 6 key points

How it affects those involved

Companies may benefit from a special merger regime under certain economic and commercial conditions, allowing the substitution of negative taxable bases.

Lifecycle

2017-10-02PublishedPublished 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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