Skip to content
Back to index
V1227-18 10 May 2018 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · régimen especial de fusiones

Rationalisation and reorganisation of business assets may be considered valid economic reasons

An entity consulted whether its restructuring operation met the valid economic reasons required to apply the special merger regime. The DGT indicates that the objectives of resource optimisation and administrative simplification described may be considered valid.

The question raised

Whether the restructuring operation can be considered to respond to valid economic reasons for the purposes of applying the special regime for mergers, demergers, contributions of assets, exchange of securities, and change of registered office of a European Company or a European Cooperative Society from one Member State to another within the European Union, as provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.

Book your free first meeting