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V3068-20 ·8 October 2020 ·consulta-vinculante Medium impact
Tax

Merger by absorption may qualify for special regime if commercial and tax requirements are met

A query was raised regarding whether a merger by absorption between two entities can apply the special tax regime for mergers. The DGT indicates that this is possible if carried out under the Structural Changes Act and complies with Article 76.1 of the Corporate Income Tax Act, provided its primary purpose is not fraud or tax advantage.

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2020-10-08PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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