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V2899-17 13 November 2017 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · canje de valores

Possibility of applying special share exchange regime under legal compliance and valid economic motives

The DGT confirms that share contributions may qualify for the special share exchange regime if the acquiring entity obtains a majority of voting rights and legal requirements are met, provided the transaction has valid economic motives and is not primarily aimed at fraud or tax evasion.

The question raised

Question raised: Whether the operation of contributing the shares of D can benefit from the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.

Apply this to a real case

What is published here, applied to a company or a specific case. The first meeting is free.

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