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Un contribuyente consulta si una operación proyectada de canje de valores de participaciones en varias entidades cumple los requisitos de neutralidad fiscal y motivo económico válido. La DGT indica que el régimen se aplicará si se adquiere la mayoría de derechos de voto y se cumplen los requisitos del artículo 80 de la LIS, siempre que no sea por fraude o evasión.
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