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A company seeking advice proposes absorbing its wholly-owned subsidiary to improve operational efficiency. The DGT rules that the transaction may qualify for tax neutrality provided it meets the requirements of the Corporate Income Tax Act (LIS) and its primary objective is not tax fraud or evasion.
This ruling clarifies that corporate restructurings driven by genuine business purposes, such as operational efficiency, can benefit from tax neutrality, even when involving the cancellation of shareholdings.
The tax team reviews your specific situation.
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