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A taxpayer asks whether a non-cash transfer of shares between entities may qualify for the special tax neutrality regime and whether the stated economic justifications are valid. The DGT states that this is possible provided the requirements of Article 87 of the LIS are met and the economic reasons given are legitimate.
Cuestión planteada Si la operación planteada, de aportación de las participaciones de la entidad D, podría acogerse al régimen fiscal especial regulado en el capítulo VII del título VII de la Ley del Impuesto sobre Sociedades. Y si los motivos económicos pueden considerarse como válidos a efectos de la aplicación del citado régimen especial.
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