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A company proposes an exchange of shares with its shareholders to establish a holding and a subsequent partial spin-off of its real estate division. The DGT states that these operations may be subject to the special corporate tax regime if legal requirements are met and economically valid reasons exist.
Cuestión planteada 1) Si las operaciones descritas pueden acogerse al régimen fiscal previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades y si existen motivos económicos válidos.
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