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A query was raised regarding whether a merger by absorption between two entities can apply the special Corporate Tax regime and if valid economic reasons exist. The DGT indicates that if the transaction meets commercial and tax requirements, and its primary purpose is not fraud or tax advantage, it may qualify for said regime.
Cuestión planteada 1) Si las operaciones descritas pueden acogerse al régimen fiscal previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades y si existen motivos económicos válidos.
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