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A family company inquires whether its plan for a non-proportional total spin-off and a reverse merger alternative may qualify for the special tax neutrality regime. The DGT responds that the spin-off does not qualify because shares in other companies do not constitute a line of business, and the reverse merger alternative is considered a transaction with a purely tax-driven purpose.
Question posed - Whether the proposed restructuring operations may qualify for the special regime under Chapter VII of Title VII of the Corporate Income Tax Law, and whether the reasons stated are considered economically valid for these purposes.
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