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Some partners inquire whether their stakes in two entities held in a holding company may benefit from the special fiscal neutrality regime. The DGT states that such regime applies if participation and residency requirements are met, and the economic justifications presented may be considered valid.
Cuestión planteada Si las aportaciones pueden acogerse al régimen de neutralidad fiscal regulado en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades, en particular, si las razones expuestas pueden considerarse como motivos económicos válidos a los efectos de lo dispuesto en el artículo 89.2 de la LIS.
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