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The consultant asks whether a share acquisition to establish a holding company may qualify for the special share exchange regime. The DGT responds that it is possible if the entity acquires a majority of voting rights, the requirements of Article 80 of the LIS are met, and the transaction has valid economic motives rather than purely fiscal objectives.
Cuestión planteada Si la operación descrita se puede acoger al régimen fiscal especial del capítulo VII del Título VII de la Ley del Impuesto sobre Sociedades 27/2014, de 27 de noviembre.
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