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Tax Neutrality: DGT doctrinal evolution
evolution::neutralidad-fiscal
Fiscal neutrality regime applicable to contribution of a business branch or assets
V5237-26
Economic merger absorption may qualify for fiscal neutrality
V5243-26
Partial dismemberment of isolated immovable assets does not allow fiscal neutrality
V5244-26
Total non-proportional spin-off requires segregated assets to constitute autonomous business units
V5245-26
Contributor's share in proindiviso deemed non-monetary contribution and not an economic activity
V5232-26
Fiscal neutrality cannot apply to contributions of rented immovable property without employees
V5228-26
Fusions and spin-offs could qualify for fiscal neutrality if legal requirements are met
V5229-26
Proportional total split may qualify for fiscal neutrality if legal requirements are met and valid economic reasons exist
V5231-26
Partial spin-off of a business activity may qualify for fiscal neutrality
V5224-26
Proportional total split of a company may qualify for tax neutrality
V5225-26
A fully owned subsidiary merger may qualify for tax neutrality
V5209-26
Neutral tax regime possible in non-proportional total split
V5211-26
Partial division of isolated assets does not allow access to tax neutrality regime
V5212-26
Neutral tax regime applicable in total split if not for fraud
V5213-26
Absorption merger may qualify for tax neutrality regime
V5186-26
Absorption merger of a fully owned subsidiary may qualify for fiscal neutrality
V5157-26
Partial financial spin-off may qualify for fiscal neutrality if conditions are met
V5158-26
Full split of a company may qualify for fiscal neutrality if LIS requirements are met
V5141-26
Fiscal neutrality cannot apply to property contribution without economic activity
V5128-26
Absorbing mergers may qualify for tax neutrality if not fraudulently motivated
V5129-26
VAT exemption in training requires authorised centre and inclusion in official study programme
V5087-26
The contribution of a line of business may qualify for the tax neutrality regime if it constitutes an autonomous economic unit
V5079-26
Proportional spin-off and subsequent absorption merger may qualify for tax neutrality
V5082-26
Contribution of a housing rental activity may qualify for fiscal neutrality
V5084-26
Total non-proportional spin-off requires autonomous activity branches for fiscal neutrality
V5074-26
V5047-26
Fiscal neutrality regime applicable to immovable activity branch contribution
V5037-26
Posibilidad de aplicar el régimen de neutralidad fiscal en la aportación de cuotas de comunidad de bienes
V5038-26
Posibilidad de aplicar el régimen de neutralidad fiscal en operaciones de fusión bajo requisitos mercantiles y legales
V5032-26
Requisitos para la aplicación del régimen de neutralidad fiscal en operaciones de fusión
V5027-26
Possibility of applying fiscal neutrality in absorption mergers if no fraud is involved
V5023-26
Requisitos para la aplicación del régimen de neutralidad fiscal en escisiones parciales
V5012-26
Full spin-off of a company may qualify for fiscal neutrality if LIS requirements are met
V5013-26
Total split may qualify for fiscal neutrality if conditions met
V5007-26
Fiscal neutrality cannot apply if commercial accounting is not maintained
V5004-26
It is possible to access the fiscal neutrality regime by contributing property shares from a community of goods to a company, subject to certain conditions
V1144-26
Possibility of applying fiscal neutrality to the contribution of a business branch to a company
V1091-26
Share donations not covered by tax neutrality; property rental may be economic activity
V1092-26
Fusion of companies may qualify for fiscal neutrality if not intended as fraud
V1095-26
V1098-26
It is possible to apply for fiscal neutrality by contributing property shares from a community of goods to a company
V1075-26
Contribution of property shares to a subsidiary may qualify for fiscal neutrality
V1059-26
Fiscal neutrality regime requires properties to be linked to economic activity for three years
V1055-26
Renting activity not considered economic if employee also performs property promotion functions
V1046-26
It is possible to apply the fiscal neutrality regime in total split and absorption merger transactions
V1044-26
Contribution of an activity branch may qualify for fiscal neutrality if it forms an autonomous economic unit
V1049-26
Absorbing mergers could qualify for tax neutrality if not aimed at fraud
V1047-26
Partial divestment of a business line may qualify for fiscal neutrality
V1039-26
Contributions of business lines may qualify for fiscal neutrality if they constitute autonomous economic units
V1028-26
Fiscal neutrality in absorption mergers possible if LIS requirements and valid economic motives met
V0996-26
Renting property constitutes an economic activity only if a full-time employee is hired
V0978-26
Partial mergers and spin-offs may qualify for fiscal neutrality under certain conditions
V0981-26
Proportional total split may qualify for tax neutrality if not for fraud
V0941-26
Spanish investment fund merger into Luxembourg SICAV may qualify for special fusion regime
V0942-26
Proportional total split may qualify for fiscal neutrality if LIS requirements met
V0904-26
Fiscal neutrality regime applicable in share exchange if legal requirements met
V0906-26
Possibility of applying fiscal neutrality regime in absorption mergers where no fraud exists
V0877-26
Non-proportional total split not covered by fiscal neutrality if segregated assets do not form autonomous business units
V0863-26
Non-proportional total split not covered by tax neutrality if assets do not constitute existing business lines
V0862-26
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