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A query was raised regarding the application of the special reorganization regime in a merger and a share contribution, as well as the exemption from Wealth Tax. The DGT determines that the merger is valid based on economic grounds and that the contribution is tax-neutral only for shareholders meeting the minimum participation threshold.
This ruling clarifies the requirements for tax neutrality in corporate reorganisations, specifically emphasizing the necessity of valid economic motives to avoid tax penalties and defining the conditions for share contributions to qualify for exemptions.
The tax team reviews your specific situation.
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