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A company inquired whether the contribution of productive units to subsidiaries, followed by a share swap, could qualify for the special regime for mergers and demergers. The DGT indicates this is possible provided a business line is proven and residency and participation requirements are met.
Cuestión planteada Si resulta de aplicación a la primera fase de la operación planteada consistente en aportar las unidades productivas de las sociedades concursadas a favor de NEWCO el régimen fiscal especial del capítulo VII del título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades. Y si los motivos económicos proporcionados son válidos a fin de justificar la aplicación del citado régimen especial.
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