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V1744-16 20 April 2016 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · canje de valores

Exchange regime may apply if legal requirements and valid economic reasons are met

A consulting company proposes a share exchange to establish a new entity (NEWCO 1) and rationalise its structure. The DGT examines whether this transaction and subsequent actions (dividend distribution or spin-off) may qualify for the special regime under the LIS.

The question raised

1) Whether the described securities exchange operation could qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.

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