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V3199-15 21 October 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · canje de valores

Possibility of applying the special regime for the exchange of securities and non-monetary contributions subject to compliance with legal requirements and valid economic reasons

A family group inquires whether the contribution of shares to a holding company may qualify for the special regime for mergers and reorganizations. The DGT determines that this is possible provided that the requirements of residence and participation are met and that the primary purpose of the operation is not tax advantage.

The question raised

Question posed: Whether the proposed operation may qualify for the special regime under Chapter VII of Title VII of the Corporate Income Tax Law, and whether the reasons stated are considered economically valid for these purposes.

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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