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An entity ceasing to be a SICAV and switching to the general tax rate has queried whether this marks the end of its tax period and if a subsequent merger could qualify for the special regime. The DGT has ruled that the transformation does indeed close the tax period and that a merger may apply the special regime provided there are valid economic reasons.
This ruling clarifies the tax implications of transitioning from a SICAV to a general tax regime, specifically regarding the closure of tax periods and the eligibility for special merger regimes based on economic justification.
The tax team reviews your specific situation.
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