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The applicant asks whether a total or partial financial spin-off can qualify for the special regime under Corporate Income Tax. The DGT rules that this is possible provided commercial and economic requirements are met, and as long as the objective is not to obtain a tax advantage through the subsequent sale of shares.
Cuestión planteada 1º) Si las operaciones descritas 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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