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The applicant asks whether a restructuring of their real estate trading companies can qualify for the special merger regime. The DGT indicates that if the operation meets commercial and tax requirements and has valid economic reasons, it could apply, although the existence of tax loss carryforwards is not sufficient grounds on its own.
Companies undergoing restructuring must demonstrate genuine economic substance beyond mere tax advantages to qualify for the special merger regime.
The tax team reviews your specific situation.
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