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A funeral services group has requested a ruling on whether its reorganization, involving total demergers and an improper merger, can benefit from the tax neutrality regime. The Directorate General for Taxes (DGT) indicates that, provided commercial and proportionality requirements are satisfied, these operations could qualify for such treatment under Corporate Income Tax.
This ruling provides clarity for corporate restructurings, confirming that tax neutrality is available for complex reorganisations as long as they are driven by genuine commercial purposes rather than purely tax-driven motives.
The tax team reviews your specific situation.
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