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The inquiry asks whether an acquisition of shares to establish a holding structure may qualify for the special share exchange regime. The DGT responds that this is possible provided the residence and valuation requirements under article 80 of the LIS are met and the transaction is not primarily aimed at fraud or tax advantage.
Cuestión planteada Si la operación descrita se podría acoger al régimen fiscal especial previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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