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V0751-23 28 March 2023 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · aportación no dineraria

Dividends from share contributions may be exempt if article 21 LIS requirements are met

A taxpayer asks about the application of the special restructuring regime to share contributions and subsequent contributions of business branches, as well as dividend exemption. The DGT states that share contributions can benefit from the special regime, but business branch contributions cannot, as they do not constitute autonomous economic units.

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