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A family proposes a merger of companies and the conversion of one of them into a real estate investment company. The DGT examines whether the transaction has valid economic motives, whether the 1% tax rate applies, and whether the shares allow for tax deductions or exemptions.
Cuestión planteada Si la operación planteada podría acogerse al régimen fiscal especial regulado en el capítulo VIII del título VII del texto refundido de la Ley del Impuesto sobre Sociedades. Y si los motivos económicos pueden considerarse como válidos a efectos de la aplicación del citado régimen especial.
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