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Una empresa consultante pregunta si la aportación de participaciones de entidades españolas por una sociedad alemana a una belga puede usar el régimen especial de fusiones y canjes de valores. La DGT indica que, al ser un canje de valores entre residentes de la UE, cumple los requisitos formales, aunque la validez de los motivos económicos dependerá de la realidad de los hechos.
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