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The consultant asks whether a share acquisition transaction may qualify for the special share exchange regime and whether valid economic grounds exist. The DGT responds that it is possible if a majority of voting rights is obtained, the requirements of Article 80 of the LIS are met, and the transaction does not primarily aim at fraud or tax evasion.
Cuestión planteada 1) Si la operación descrita puede 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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