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The inquiry seeks clarification on the application of the tax neutrality regime in mergers involving tax savings. The DGT rules that the regime applies as long as the primary objective is not fraud or evasion, thereby permitting tax planning through choice of option.
This ruling provides legal certainty for corporate restructurings, confirming that tax-efficient merger strategies are permissible provided they are based on legitimate economic motives rather than evasion.
The tax team reviews your specific situation.
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