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The applicant asks whether a series of capital contributions followed by a merger can qualify for the special tax regime for corporate reorganisations. The DGT rules that this is possible provided that legal requirements are satisfied and the primary purpose of the operation is not to obtain a tax advantage.
Companies undertaking restructuring through capital contributions and mergers can benefit from tax neutrality, provided they can demonstrate valid economic grounds beyond mere tax avoidance.
The tax team reviews your specific situation.
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