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Una sociedad inmobiliaria consulta si la escisión total de su patrimonio para facilitar la sucesión familiar puede acogerse al régimen especial de neutralidad fiscal. La DGT responde que, si la operación se realiza en el ámbito mercantil y cumple los requisitos de la LIS, podría aplicarse dicho régimen, siempre que no tenga como objetivo principal el fraude o la evasión fiscal.
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