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Contributors inquire whether transferring shares from a company to a holding may qualify under the special restructuring regime. The DGT states that continuous holding and minimum participation thresholds would be met if more than 5% of shareholders' equity is transferred, subject to the existence of genuine economic motives.
Contributors may qualify for the special non-cash contribution regime if they transfer more than 5% of a company's equity to a holding, provided there are genuine economic reasons behind the transfer and uninterrupted ownership.
The fiscal team reviews your specific situation.
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