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A company queried whether a merger between two operating companies could qualify for the special Corporate Tax regime. The DGT ruled that this is possible provided the transaction meets commercial requirements and aims for economic restructuring rather than solely exploiting tax loss carryforwards.
Companies seeking to restructure must demonstrate genuine commercial substance and economic purpose to qualify for tax benefits under the special merger regime, preventing the use of mergers solely for tax avoidance purposes.
The tax team reviews your specific situation.
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