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A company proposes a share exchange whereby it transfers its full shareholdings in 15 entities to another entity in exchange for new shareholdings. The DGT states that the operation may be subject to the fiscal neutrality regime if the conditions of Article 80 of the LIS are met and the primary objective is not fraud.
Cuestión planteada Si la operación descrita puede acogerse al régimen fiscal previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades y si existen motivos económicos válidos.
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