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Siblings have consulted whether their restructuring through contributions of shares can qualify for the special Corporate Tax regime. The DGT indicates that, provided the requirements for participation and residence are met, reasons relating to family organisation and operational efficiency are considered valid economic motives.
Cuestión planteada Si la operación de reestructuración 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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