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El consultante pregunta si su aportación de participaciones en tres entidades a una nueva sociedad holding constituye un motivo económico válido para usar el régimen especial. La DGT indica que se aplicará el régimen si se cumplen los requisitos de participación y posesión del artículo 87.1 de la LIS y si la operación no tiene como objetivo principal el fraude o la evasión fiscal.
The fiscal team reviews your specific situation.
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