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V2497-24 ·9 December 2024 ·consulta-vinculante Medium impact
Tax

Negative tax bases of an absorbed company may be offset provided there is no double compensation

The taxpayer asks whether they can offset the negative tax bases of entity F following its acquisition and absorption. The DGT rules that the limitation due to a change of control does not apply if the requirements of letter c) are not met and that, in tax-neutral mergers, losses may be offset as long as no double compensation of those losses occurs.

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2024-12-09PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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