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A family group asks whether a three-company merger followed by a full spin-off can benefit from the special corporate tax regime. The DGT states that such arrangements may qualify for the regime's benefits and ITPAJD exemption, provided fiscal and commercial requirements are met and there is no primary objective of tax fraud or evasion.
Cuestión planteada 1. Si las operaciones descritas pueden 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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