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Una empresa de alquiler de inmuebles consulta si su plan de escisión total con liquidación y reparto no proporcional de activos puede acogerse al régimen de neutralidad fiscal. La DGT responde que, al incluir la liquidación de la sociedad y no acreditarse la existencia de ramas de actividad autónomas y diferenciadas, no es posible aplicar dicho régimen.
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