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A company queried whether a merger of inactive companies could qualify for the special Corporate Tax regime. The DGT indicates that for this to apply, the transaction must meet commercial requirements and have valid economic motives, rather than being driven solely by the intention to utilise tax losses.
Companies undertaking mergers must ensure they possess genuine commercial substance and economic justification to benefit from tax neutrality, as purely tax-driven reorganisations may be disqualified from the special regime.
The tax team reviews your specific situation.
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