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A query was raised regarding whether the merger of a subsidiary into its parent company can benefit from the special tax regime of the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) indicates that this regime may apply provided that commercial requirements are met and valid economic reasons exist.
Companies undergoing restructuring through mergers may benefit from tax neutrality and the carry-forward of tax losses, provided they demonstrate genuine economic substance.
The tax team reviews your specific situation.
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