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A Spanish resident enquires whether transferring the fiscal residence and registered office of three foreign companies to Spain and then merging them with a Spanish company triggers taxation. The DGT responds that moving the fiscal residence does not generate income under the Personal Income Tax (IRPF) or the Non-Resident Income Tax (IRNR), and that no capital gain arises for the shareholder if the legal personality remains unchanged.
The tax team reviews your specific situation.
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