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A shareholder asks whether contributions of shares from several entities to a new company (NEWCO) can qualify for the special regime under the LIS. The DGT confirms this is possible if the entities meet participation and activity requirements, and if the stated management and risk separation reasons are economically sound.
The clarification enables non-cash share contributions from multiple entities to a new company to qualify under the special LIS regime, provided economic justification for management and risk separation is demonstrated.
The tax team reviews your specific situation.
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