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A query was raised regarding whether a merger by absorption of a wholly-owned subsidiary can apply the special tax neutrality regime and if the economic reasons are considered valid. The DGT ruled that if the merger is carried out in a commercial context for valid economic reasons, it may qualify for the regime, and that dividends and income from the transfer could be exempt provided the requirements of Article 21 of the LIS are met.
The tax team reviews your specific situation.
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