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A consulting company asks whether it can apply the special merger regime to absorb its subsidiaries, whether economic motives are valid, and how it would affect negative tax bases. The DGT responds that if the operation meets commercial and LIS requirements, fiscal neutrality and tax base substitution may apply.
Cuestión planteada - Si es posible acogerse al régimen especial de las fusiones, escisiones, aportaciones de activos, canje de valores y cambio de domicilio social de una Sociedad Europea o una Sociedad Cooperativa Europea de un Estado miembro a otro de la Unión Europea establecido en el Capítulo VIII del Título VII de la LIS.
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