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Una sociedad sanitaria consulta si puede realizar una escisión total no proporcional (atribuyendo participaciones de forma distinta a los socios) acogiéndose al régimen de neutralidad fiscal. La DGT responde que, para que la escisión no proporcional sea fiscalmente neutra, los patrimonios segregados deben constituir ramas de actividad autónomas según la LIS.
The tax team reviews your specific situation.
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