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The taxpayer inquired whether a total demerger could qualify for the special tax regime. The DGT ruled that if the demerger meets commercial requirements and is carried out for valid economic reasons rather than purely tax-driven purposes, the special regime is applicable.
Cuestión planteada Si la operación descrita puede acogerse al régimen fiscal especial del capítulo VII del Título VII de la Ley del Impuesto sobre Sociedades 27/2014, de 27 de noviembre.
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