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A real estate company has enquired whether its double merger-by-absorption operation can qualify for the special Corporate Tax regime. The DGT has ruled that for company B, it is necessary to allocate values to its shareholders that are representative of the absorbing company's capital; otherwise, it will not comply with the regime.
This ruling clarifies the requirements for maintaining tax neutrality in complex merger structures, specifically regarding the allocation of capital values to shareholders.
The tax team reviews your specific situation.
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