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The consultant asks whether a share acquisition transaction may qualify for the special share exchange regime. The DGT confirms it is possible if voting rights and residency requirements are met, provided the transaction does not primarily aim at tax fraud or evasion.
Cuestión planteada Si la operación descrita puede acogerse al régimen 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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