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A family company owned by a father and his three children proposed a total proportional split into two new companies, allocating shares proportionally to their original participation. The DGT confirmed that the operation falls under the fiscal neutrality regime of the LIS, as the proportional distribution does not require the split assets to be business branches, and the objective of separating management to facilitate family succession is considered a valid economic purpose.
The operation qualifies for fiscal neutrality under the LIS due to proportional allocation and legitimate succession objectives, without requiring the split assets to form business branches.
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