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A natural person asks whether they can apply the special regime for mergers and non-cash contributions by transferring shares from their companies to a new holding. The DGT states that this is possible if the shareholding and ownership requirements are met, provided the transaction has valid economic motives.
The ruling clarifies conditions under which non-cash share transfers to a holding company may qualify for the special regime, ensuring alignment with economic rationale and ownership rules.
The tax team reviews your specific situation.
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