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A taxpayer has enquired whether the contribution of shares from five companies to a holding company constitutes a securities exchange under the special regime. The DGT indicates that this regime may apply provided that requirements regarding majority voting rights, residency, and the absence of tax fraud are met.
Cuestión planteada Si la aportación de participaciones de las distintas sociedades existentes a la holding se encuentra dentro del régimen especial del capítulo VIII del título VII del TRLIS. En concreto si sería un canje de valores.
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