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A query was raised regarding whether the contribution of shares by two individuals to a company could qualify for the special regime under the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) ruled that only contributions meeting the minimum 5% shareholding threshold and the requirements for uninterrupted ownership can benefit from this regime.
Question posed: Whether the described operation may qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
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