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The applicant asks whether a share swap operation can qualify for the special regime under Corporate Income Tax and if the underlying reasons are valid. The DGT rules that it is possible to meet the legal requirements and that the presented reasons regarding centralisation and management are economically valid.
Cuestión planteada Si la operación de reestructuración planteada podría acogerse al régimen fiscal especial regulado en el capítulo VIII del título VII del texto refundido de la Ley del Impuesto sobre Sociedades. Y si los motivos económicos pueden considerarse como válidos a efectos de la aplicación del citado régimen especial.
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