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V0043-17 13 January 2017 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · consolidación fiscal

Mergers by absorption under the special tax neutrality regime allow for income deferral and non-inclusion of income from share cancellation

A parent company (X) seeks guidance regarding the dissolution of its subsidiary (Y) within a tax consolidation group. The DGT examines whether the transaction should be carried out via a merger not subject to the special regime or via a merger qualifying for the tax neutrality regime.

The question raised

Question raised 1. Merger by absorption without opting for the special tax neutrality regime:

Apply this to a real case

What is published here, applied to a company or a specific case. The first meeting is free.

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