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A shareholder asks whether contributing shares in two entities to a new company (NEWCO) can be taxed under the value exchange regime. The DGT states that the tax-neutral regime applies if voting majority and other LIS requirements are met, provided it is not for fraud or evasion.
Cuestión planteada Si, de acuerdo con lo expuesto, la operación descrita podría 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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