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Consultants ask whether a share exchange enabling one company to acquire 100% of another can benefit from the special fiscal neutrality regime. The DGT confirms it is possible provided residence requirements are met and the transaction is not primarily aimed at tax fraud or evasion.
Question posed: Whether the tax neutrality regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, is applicable to the proposed securities exchange operation.
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