Mergers and the revenue test
The slides explain special revenue rules for mergers and demergers, rather than testing each acquired entity separately against EUR750 million. For the illustrated merger provisions, revenues of the combining groups can be aggregated for relevant pre-merger years and the first merged year. Financial-year differences require the prescribed matching method. Acquiring a single constituent entity does not automatically constitute the same type of group merger. Identify the transaction category before rebuilding the two-out-of-four-year revenue assessment.
Other structural changes
The module covers entities joining or leaving a group, transfers of assets and liabilities, joint ventures and multi-parent arrangements. Formal multi-parent structures can be treated as one MNE group using a single consolidated-financial-statement framework where the conditions are met. Consolidation, ownership and transaction-specific rules remain important even when a commercial organisation chart appears unchanged. Maintain the effective dates, accounting treatment and pre-transaction amounts so that the income and tax consequences can be assigned to the correct group and year.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
Read the official PDF ↗