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A query was raised regarding the procedure when two tax groups sharing the same parent entity (resident in the Basque Country) must unify following the entry into force of the Corporate Income Tax Act. The Directorate General for Taxes (DGT) ruled that both must be integrated into a single group, allowing for the dissolution of one so that its subsidiaries can be incorporated into the other.
This ruling clarifies the restructuring process for tax groups involving entities subject to Basque regional tax regulations, ensuring legal certainty during corporate reorganisations.
The tax team reviews your specific situation.
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