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A taxpayer asks whether contributing shares in an existing entity allows applying the special regime of fiscal neutrality and whether this violates succession and donations tax reduction requirements. The DGT responds that fiscal neutrality may apply if LIS requirements are met, and that subsequent contributions do not breach the requirement to maintain acquired assets under succession tax rules.
Cuestión planteada Si resulta de aplicación a la operación el régimen fiscal especial del Capítulo VII del Título VII de la Ley 27/2014, del Impuesto sobre Sociedades, (en adelante, LIS), y si los motivos enunciados constituyen motivos económicos válidos a efectos de lo previsto en el artículo 89.2 de la LIS
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