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The consultation examines whether three operations (segregation of a business line, share swap, and contribution of real estate) can qualify for the special regime under the TRLIS. The DGT determines that this is possible provided that the requirements for economic unity, majority of voting rights, and minimum participation are met, and that valid economic reasons exist.
This ruling clarifies the conditions under which corporate restructuring operations can benefit from tax neutrality under the special reorganization regime, specifically regarding non-monetary assets and business line transfers.
The tax team reviews your specific situation.
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