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The DGT confirms that a share acquisition to establish a holding company may qualify for the special share exchange regime if a majority of voting rights is obtained, LIS article 80 requirements are met, and the transaction has valid economic motives rather than purely fiscal objectives.
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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