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La consultante pregunta si una operación de canje de valores para crear una holding cumple los requisitos del régimen especial de la LIS y si tiene motivos económicos válidos. La DGT responde que se podrá aplicar dicho régimen si la entidad adquiere la mayoría de derechos de voto y se cumplen los requisitos del artículo 80, siempre que no sea por fraude o evasión fiscal.
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