On 18 June 2013, the Supreme Court gave its decision in International Engines S.A., on the conditions to benefit from a tax-free reorganization within the context of an economic group. Details of the case are summarized below.

(a) Facts. A resident company, Industria de Máquinas Agrícolas Sur S.A. (IMASUR), merged into a controlled subsidiary of International Engines S.A., another resident…

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