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A query was raised regarding whether a non-monetary contribution of shares can qualify for the special corporate restructuring regime. The DGT indicates that this regime is applicable provided that the requirements for participation and ownership are met, and the transaction is driven by valid economic reasons rather than purely tax-driven motives.
This ruling clarifies the conditions under which non-monetary contributions can benefit from tax advantages under the corporate restructuring regime, emphasizing the necessity of genuine economic substance over tax avoidance.
The tax team reviews your specific situation.
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