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The applicant asks whether a total demerger followed by a share exchange can qualify for the special regime under Corporate Income Tax. The DGT rules that this is possible provided that all legal requirements are met and the primary purpose of the transaction is not to obtain a tax advantage.
Cuestión planteada 1º) Si las operaciones descritas de escisión total y canje de valores pueden acogerse al régimen fiscal especial previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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