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An entity has requested clarification on whether a corporate merger can apply the special Corporate Tax regime and if its underlying motives are considered valid. The DGT indicates that if the transaction meets both commercial and tax requirements, and is carried out for economic reasons rather than solely to obtain tax advantages, it may qualify for the regime.
Question posed 1. Whether the projected operation may benefit from the special tax regime regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, and whether the economic reasons may be considered valid for the purposes of applying the special regime.
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