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Un matrimonio consulta si la aportación de participaciones de cuatro sociedades a una nueva entidad (Newco) puede acogerse al régimen de neutralidad fiscal. La DGT responde que es posible siempre que la entidad adquiera la mayoría de derechos de voto y se cumplan los requisitos del artículo 80 de la LIS, sin que el objetivo principal sea el fraude o la ventaja fiscal.
The fiscal team reviews your specific situation.
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