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A query was raised regarding whether a merger between companies within the same group can apply the special Corporate Tax regime and if valid economic reasons exist. The DGT indicates that this may apply if commercial and tax requirements are met, and that the transfer will not be subject to VAT as it constitutes an autonomous economic unit.
This ruling clarifies the conditions under which intra-group mergers can benefit from tax neutrality and VAT exemption, provided they meet specific commercial and structural criteria.
The tax team reviews your specific situation.
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