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A viticulture company has enquired whether a merger with its real estate subsidiary can utilise the special Corporate Tax regime and if the economic motives are valid. The DGT indicates that, provided mercantile and economic requirements are met, the operation may qualify for the special regime, be not subject to VAT, and be exempt from ITP.
Question posed: Whether the projected operation 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 reasons may be considered valid for the purposes of applying the special regime.
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