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Some partners inquire whether transferring their shares in two entities to a holding company may qualify for the fiscal neutrality regime. The DGT states that this is possible if the participation and ownership requirements are met, and the reasons given for reorganisation and family control may be considered valid economic grounds, subject to verification of facts.
Cuestión planteada Si las aportaciones pueden acogerse al régimen de neutralidad fiscal regulado en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades, en particular, si las razones expuestas pueden considerarse como motivos económicos válidos a los efectos de lo dispuesto en el artículo 89.2 de la LIS.
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