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The taxpayer asks whether a merger operation may apply the special regime of the Corporate Income Tax. The DGT responds that, for this to occur, the operation must meet commercial and tax requirements and be carried out for valid economic reasons without the primary purpose being the exploitation of tax loss carryforwards.
Question posed: Whether the described operation may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
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