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A company asks whether creating a holding company through share exchange and subsequent dividend payments in kind qualifies for the special share exchange regime. The DGT confirms the operation constitutes a share exchange and that the stated economic grounds are valid.
Cuestión planteada 1. Si en la operación de canje de las participaciones de la entidad consultante con las de una nueva sociedad holding conforme a los objetivos y forma planteada se le puede aplicar el régimen fiscal del canje de valores previsto en el capítulo VII del título VII de la Ley del Impuesto sobre Sociedades.
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