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A query was raised regarding whether a merger by absorption between two entities within the same consolidated group can apply the special merger regime. The DGT indicates this is possible provided commercial and tax requirements are met, and the transaction is driven by valid economic reasons rather than being solely for tax purposes.
Cuestión planteada Si a la fusión por absorción descrita le es de aplicación el régimen especial regulado en el capítulo VII del título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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