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A couple asks whether transferring their stakes in six companies to a new holding company qualifies for the special exchange regime. The DGT confirms it is possible if the holding acquires a majority of voting rights, the conditions of Article 80 of the LIS are met, and the transaction has genuine economic justification rather than a purely fiscal objective.
Cuestión planteada Si la operación descrita se podría acoger al régimen fiscal especial previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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