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Una gestora consulta si la fusión de un fondo de inversión español en una SICAV luxemburguesa puede aplicar el régimen especial de fusiones de la LIS. La DGT indica que es posible si se cumplen los requisitos de la ley y la normativa financiera, aunque las rentas de la entidad absorbida tributarán si los activos no quedan en un establecimiento permanente en España.
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