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A physical person asks whether contributions of shares from two companies to a new holding may qualify for the special tax neutrality regime. The DGT states this is possible if minimum 5% ownership, uninterrupted possession, and valid economic reasons are met.
The ruling clarifies conditions under which non-monetary share contributions to a holding company may qualify for tax neutrality, supporting cross-company share reallocations under specific criteria.
The tax team reviews your specific situation.
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