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A natural person enquires whether contributions of shares from several entities to a Spanish resident company may qualify for the special regime. The DGT confirms this is possible provided the requirements of ownership and participation are met, and the transaction is not primarily aimed at tax fraud or avoidance.
The ruling clarifies conditions under which non-cash share contributions to Spanish companies can qualify for the special regime, ensuring transparency and preventing tax evasion.
The fiscal team reviews your specific situation.
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