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Un contribuyente consulta si la aportación de participaciones de dos entidades a una sociedad holding mediante canje de valores permite aplicar el régimen especial de neutralidad fiscal. La DGT responde que es aplicable siempre que la entidad beneficiaria obtenga la mayoría de derechos de voto y se cumplan los requisitos del artículo 80 de la LIS, sin que la operación tenga como fin principal el fraude o la evasión fiscal.
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