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Consultants ask whether the reasons for their business restructuring are valid for applying the special non-cash contribution regime. The DGT states that the stated grounds may be considered valid, provided legal requirements are met and the primary objective is not to obtain a fiscal advantage.
Cuestión planteada Si los motivos económicos expuestos son válidos a los efectos de que las operaciones planteadas puedan beneficiarse del régimen especial de fusiones, escisiones, aportaciones de activos y canje de valores 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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