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A natural person enquires whether contributions of shares from three companies to a new entity (Newco) may qualify for the special restructuring regime. The DGT determines that if the requirements of ownership and participation are met, the transaction constitutes a non-cash contribution subject to the fiscal neutrality regime.
The transaction qualifies as a non-cash contribution under the fiscal neutrality regime if ownership and participation conditions are met.
The tax team reviews your specific situation.
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