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A query was raised regarding whether a partial demerger and a share exchange can qualify for the special regime of Corporation Tax. The DGT concludes that this is possible, provided that the legal requirements are met and the transactions are supported by valid economic reasons.
Question raised: Whether the described operations may benefit from 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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