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A family holding company (F) proposes to absorb another company within the same group (O). The DGT confirms that the transaction may qualify for fiscal neutrality under Article 76.1 LIS and the commercial framework of Royal Decree-Law 5/2023, as valid economic grounds (rationalisation, cost reduction, asset strengthening) are alleged, and no entity has negative bases or pending deductions.
The tax team reviews your specific situation.
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