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The applicant asks whether the absorption of one entity by another can qualify for the special merger regime under Corporate Income Tax. The DGT indicates that the transaction may qualify for this regime if it meets commercial and economic requirements, provided its primary purpose is not tax fraud or evasion.
Cuestión planteada Si la operación planteada puede acogerse al régimen fiscal especial recogido en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades y si las razones en las que se fundamenta la operación pueden considerarse como válidos a efectos de la aplicación del citado régimen especial.
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