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The applicant asks whether a share exchange and a partial financial demerger can qualify for the special regime under the Corporate Income Tax Act. The DGT rules that this is possible provided that legal and commercial requirements are met and the stated reasons for reorganization are economically valid.
Cuestión planteada Si las operaciones descritas de canje de valores y escisión financiera impropia pueden 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.
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