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An entity has requested clarification on whether a merger between two real estate companies can benefit from the special tax regime. The DGT indicates that to qualify, the operation must meet the requirements of the Structural Changes Act and the TRLIS, and its primary purpose must not be to obtain a tax advantage.
Companies planning restructuring through mergers must ensure compliance with both the Structural Changes Act and the TRLIS, demonstrating genuine economic substance to avoid being denied the special tax regime due to tax avoidance motives.
The tax team reviews your specific situation.
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