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An entity has requested clarification on whether a merger by absorption involving a company wholly owned by the same shareholder can qualify for the special tax regime. The Directorate General for Taxes (DGT) has ruled that this is possible, provided that commercial requirements are met and valid economic reasons exist.
This ruling provides legal certainty for corporate restructurings involving single-shareholder entities, confirming that tax neutrality can be maintained if the transaction is justified by economic motives rather than purely tax-driven purposes.
The tax team reviews your specific situation.
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