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 company, under a tax-free reorganization scheme.
In 1995, International Engines S.A.filed a …