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A taxpayer asks whether contributions of shares in several entities to a new company (NEWCO) can qualify for the LIS special regime. The DGT states that this is possible provided the participation and activity requirements are met, and the transaction is not primarily aimed at tax fraud or avoidance.
Cuestión planteada Si la operación planteada 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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