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V0926-16 10 March 2016 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · canje de valores

Fusion and share swaps may qualify under special regime if valid economic reasons exist

A natural person enquires whether a share swap and merger restructuring may qualify for the special regime of the Corporate Income Tax. The DGT responds that this is possible provided the LIS requirements are met and the transaction takes place in the commercial sphere with valid economic grounds.

The question raised

1) Whether the described operations may benefit from the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.

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