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An entity has requested clarification on whether a series of demerger, merger, contribution of shares, and share exchange operations may qualify for the special tax regime under the TRLIS. The DGT has ruled that this is possible provided that all legal requirements are met and the primary purpose of the operation is not to obtain a tax advantage.
Cuestión planteada Si las operaciones descritas pueden acogerse al régimen fiscal especial del capítulo VIII del Título VII del Texto Refundido de la Ley del Impuesto sobre Sociedades, aprobado por Real Decreto Legislativo 4/2004, de 5 de Marzo, y cuál sería el tratamiento contable de las operaciones proyectadas.
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