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The query examines whether a non-monetary contribution of shares and a total demerger can qualify for the special tax regime. The DGT rules that this is possible provided the requirements of the TRLIS are met and the transaction is supported by valid economic reasons.
Cuestión planteada Si las operaciones descritas de aportación no dineraria y escisión total pueden acogerse al régimen fiscal especial del capítulo VIII, del título VII del Texto Refundido de la Ley del Impuesto sobre Sociedades aprobado por Real Decreto Legislativo 4/2004, de 5 de Marzo.
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