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Un socio consulta si la aportación de sus participaciones en dos entidades a una nueva sociedad (NEWCO) puede tributar bajo el régimen de canje de valores. La DGT señala que se aplicará la neutralidad fiscal si se cumplen los requisitos de mayoría de votos y los demás preceptos de la LIS, siempre que no sea por fraude o evasión.
The fiscal team reviews your specific situation.
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