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The DGT confirms that a share acquisition to establish a holding company may qualify for the special exchange regime, provided legal requirements are met and the transaction is not primarily aimed at tax fraud or evasion.
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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