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Some partners inquire whether transferring their shares in two entities to a holding company may qualify for the fiscal neutrality regime. The DGT states that this is possible if the participation and ownership requirements are met, and the reasons given for reorganisation and family control may be considered valid economic grounds, subject to verification of facts.
The guidance clarifies that non-monetary contributions to a holding company may qualify for fiscal neutrality under specific conditions, particularly when linked to corporate reorganisation and family control, provided the economic rationale is substantiated.
The fiscal team reviews your specific situation.
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