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A company has requested a ruling on whether its merger by absorption meets the requirements for the special tax regime. The DGT indicates that the transaction must be carried out under the Structural Changes Act and comply with Article 76.1 of the Corporate Income Tax Act, ensuring that the primary objective is not tax advantage.
Cuestión planteada Si la operación de fusión descrita reúne los requisitos exigidos para la aplicación del régimen fiscal especial regulado en el Capítulo VII del Título VII de la LIS.
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