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A query was raised regarding whether a merger between companies within a family group could benefit from the special Corporate Tax regime. The DGT indicates that, provided it complies with commercial regulations and Article 76.1.a) of the LIS, it may qualify as long as its primary purpose is not tax evasion or obtaining an unfair tax advantage.
This ruling clarifies the conditions under which family business restructurings can access tax benefits, emphasizing the necessity of genuine economic substance over tax-driven motives.
The tax team reviews your specific situation.
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