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A query is made as to whether a merger and a non-proportional total demerger may apply the special Corporate Income Tax regime. The DGT determines that the demerger does not meet the requirements because the asset blocks do not constitute autonomous business lines, although the economic motives presented could be valid.
Question posed: Whether the projected operations may qualify for 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 motives can be considered valid for the purposes of applying the special regime.
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