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The inquiry asks whether a securities exchange operation and a total spin-off may qualify for the special tax neutrality regime. The DGT responds that it is possible provided that the requirements of the Corporate Income Tax Act are met and the primary objective is not tax advantage.
Question posed: Whether the described operations could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
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