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V3527-16 ·27 July 2016 ·consulta-vinculante Medium impact
FISCAL

Negative taxable bases can be offset after foreign merger if ownership existed prior

The DGT confirms that a Spanish company may offset negative taxable bases following a merger of its German parent companies, as the Spanish holding already belonged to the same group prior to the merger.

In 5 key points

How it affects those involved

Spanish companies involved in cross-border mergers may now offset negative taxable bases if the holding was part of the same group before the merger.

Lifecycle

2016-07-27PublishedPublished 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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