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An individual inquires whether the contribution of shares from two companies to a third may qualify for the special tax neutrality regime and whether the income derived from the dissolution of the contributing companies would be exempt. The DGT responds that, upon fulfillment of the requirements regarding the percentage of participation, uninterrupted ownership, and valid economic reasons, the special regime and the corresponding exemption are applicable.
Question raised 1) 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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