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The consultant asks whether a reorganisation transaction creating a holding company may qualify for the special regime under the LIS. The DGT states that this will depend on whether the conditions for share exchange or non-cash contributions are met and that the transaction is not primarily aimed at obtaining a fiscal advantage.
Cuestión planteada Si la operación descrita puede acogerse 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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