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A query was raised regarding whether a merger operation can apply the special tax regime for European Companies. The Directorate General for Taxes (DGT) indicates that this is possible provided the requirements of the Structural Changes Act and the Corporate Income Tax Law (TRLIS) are met, and the operation is supported by valid economic reasons.
This ruling provides legal certainty for cross-border restructurings involving European Companies, confirming that tax benefits are available if the transaction is not driven solely by tax advantages.
The tax team reviews your specific situation.
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