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A query was raised regarding whether the merger of three advisory entities could qualify for the special merger regime and if valid economic reasons exist. The DGT indicates that the operation may qualify for the regime if it meets commercial and Corporate Tax requirements, provided its primary purpose is not fraud or tax advantage.
Companies undergoing restructuring must ensure that mergers are driven by genuine economic motives rather than tax avoidance to benefit from tax neutrality.
The tax team reviews your specific situation.
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