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A consulting company proposes a reverse merger where its subsidiary A1 absorbs the parent company A, which holds tax loss carryforwards. The DGT rules that the transaction may qualify for tax neutrality provided it meets the requirements of the Corporate Income Tax Act and its primary objective is not tax fraud or evasion.
This ruling provides legal certainty for corporate restructurings involving reverse mergers, confirming that tax neutrality is available as long as the transaction is driven by genuine economic motives rather than tax avoidance.
The tax team reviews your specific situation.
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