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A business group has enquired whether its restructuring through mergers can benefit from the special regime for Corporate Income Tax. The Directorate General for Taxes (DGT) responds that this is possible provided the operation serves genuine economic purposes rather than purely tax-driven ones, and further details the treatment of tax loss carryforwards.
Companies undertaking corporate restructuring must ensure that mergers are driven by substantive economic motives to qualify for tax benefits and avoid being classified as purely tax-avoidance schemes.
The tax team reviews your specific situation.
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