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A taxpayer asks whether a value exchange restructure can benefit from the special regime of Corporate Income Tax and if the stated economic justifications are valid. The DGT confirms that residency requirements can be met and that the stated reasons for 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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