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A query was raised regarding whether a merger operation can apply the special tax regime for European Companies. The DGT indicates that this must be carried out under the Structural Changes Act and comply with Article 76.1.c) of the Corporate Tax Act.
Cuestión planteada Si la operación descrita puede acogerse al régimen fiscal especial previsto en el Capítulo VII del título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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