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A natural person enquires whether transferring their shares in two companies to a new holding company may qualify for the special restructuring regime. The DGT responds that this is possible if the new company obtains a majority of voting rights and legal requirements are met, provided the transaction is not purely for tax purposes.
The regime allows share exchanges between companies to be treated as tax-neutral under certain conditions, promoting business restructurings without triggering fiscal consequences.
The tax team reviews your specific situation.
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