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A company has requested a ruling on whether contributing shares of a subsidiary to a new entity meets the requirements of the special regime for non-monetary contributions. The DGT indicates that residency and minimum shareholding requirements must be met, and that the economic reasons provided may be valid.
Question posed: Whether the non-monetary contribution by the inquiring entity in favor of entity N, consisting of shares representing 41.70% of entity M, meets the requirements to qualify for the special non-monetary contribution mechanism provided for in Article 87 of the LIS.
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