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V2896-17 ·13 November 2017 ·consulta-vinculante Medium impact
Tax

Merger of Spanish and Luxembourgish SICAVs may qualify for special regime if valid economic reasons exist

A Spanish SICAV has queried whether its merger with a Luxembourgish entity can qualify for the special merger regime and if its motives are considered economic. The Directorate General for Taxes (DGT) indicates that the regime could apply provided that the acquired assets are not assigned to a permanent establishment in Spain and the primary purpose of the transaction is not tax advantage.

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2017-11-13PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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