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The consultant seeks to centralise holdings in entities A and B via a new holding company through a share exchange. The DGT confirms the operation may qualify for the special regime if the holding company obtains a majority of voting rights and legal requirements are met, provided it is not for fraud or tax evasion.
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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