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The applicant asks whether a merger of companies intended to centralise activity and optimise resources can apply the special Corporate Tax regime, and what the impact is on VAT and Stamp Duty (ITP/AJD). The DGT indicates that the reasons provided could be valid if legal requirements are met, and that the transfer of a business assets portfolio is not subject to VAT.
Companies planning restructuring through mergers should ensure they can document valid economic motives to benefit from special tax regimes and avoid VAT on asset transfers.
The tax team reviews your specific situation.
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