As tecnologias radicalmente novas geram lucros por meio da conversão eficiente em processos, produtos e serviços. Entretanto, para esta conversão, empresas necessitam desenvolver novas capacidades e aprimorar as existentes para tornarem-se empresas aptas ao desenvolvimento e comercialização de novos produtos. Esta tese apresenta uma sistemática para a avaliação da evolução e (re)configuração das capacidades para a gestão do Processo de Conversão de Tecnologia em Produtos e Serviços (PCTPS). Este tipo de avaliação adequa-se no contexto de projetos de desenvolvimento radicais, como o que ocorre em novas empresas de base tecnológica, com destaque às empresas do tipo spin-off acadêmico. A sistemática foi representada por meio de um framework de forma a atender as premissas identificadas a partir da literatura. Para fins de avaliação das capacidades, foram elaborados constructos de níveis de desenvolvimento e de ajuste de capacidades e, a partir destes, foram propostas métricas para avaliação. A sistemática e seus componentes foram validados através da avaliação junto a especialistas, análise experimental e simulação e aplicação em um estudo de caso de um empreendimento liderado por uma spin-off acadêmica para análise de usabilidade. Para operacionalizar a sistemática proposta, métodos, formulários e índices foram incorporados em uma ferramenta. Esta ferramenta apresenta-se como um método de decisão multicriterial, com uma estrutura de combinação dos índices e de elaboração de relatórios. A sistemática auxilia as empresas a avaliarem suas capacidades e identificar como combiná-las e desenvolve-las para criar uma estrutura organizacional com políticas e rotinas definidas para coordenar e (re)configurar suas capacidades na condução do PCTPS. / Radically new technologies only generate returns by their efficient conversion into processes, products and services. However, enterprises need to develop new capabilities and improve the existing ones to become able to the development and commercialization of new products. This thesis presents, in the context of process of technology conversion to products and services, a model for performance measurement through the capabilities evolution and (re)configuration. This kind of evaluation is adequate in the context of radical development projects, as ones occurring in new technology based companies, with distinction to academic spin-off companies. The model was initially composed by a framework that incorporated and attended the promises identified from the literature. This framework was then embodied with tools and practices. To enable the capabilities evaluation, were defined the constructs for measurement of capabilities adjustment and development levels. From these constructs, the metrics for evaluation were proposed. The model was validated by evaluation with specialists, experimental and simulation analysis and usability test in a case. Methods, forms, and indexes were incorporated in a tool to enable the model operationalization. This tool was designed as a multi-criteria decision method that presents a structure for index combining and for report elaboration. The model supports the companies to evaluate their capabilities and identify how to combine them and develop them to create an organizational structure. This evaluation is understood as a guide for policies and routines definition in the process of coordination and (re)configuration of capabilities during the conduction of the new technologies conversion into processes, products and services.

As tecnologias radicalmente novas geram lucros por meio da conversão eficiente em processos, produtos e serviços. Entretanto, para esta conversão, empresas necessitam desenvolver novas capacidades e aprimorar as existentes para tornarem-se empresas aptas ao desenvolvimento e comercialização de novos produtos. Esta tese apresenta uma sistemática para a avaliação da evolução e (re)configuração das capacidades para a gestão do Processo de Conversão de Tecnologia em Produtos e Serviços (PCTPS). Este tipo de avaliação adequa-se no contexto de projetos de desenvolvimento radicais, como o que ocorre em novas empresas de base tecnológica, com destaque às empresas do tipo spin-off acadêmico. A sistemática foi representada por meio de um framework de forma a atender as premissas identificadas a partir da literatura. Para fins de avaliação das capacidades, foram elaborados constructos de níveis de desenvolvimento e de ajuste de capacidades e, a partir destes, foram propostas métricas para avaliação. A sistemática e seus componentes foram validados através da avaliação junto a especialistas, análise experimental e simulação e aplicação em um estudo de caso de um empreendimento liderado por uma spin-off acadêmica para análise de usabilidade. Para operacionalizar a sistemática proposta, métodos, formulários e índices foram incorporados em uma ferramenta. Esta ferramenta apresenta-se como um método de decisão multicriterial, com uma estrutura de combinação dos índices e de elaboração de relatórios. A sistemática auxilia as empresas a avaliarem suas capacidades e identificar como combiná-las e desenvolve-las para criar uma estrutura organizacional com políticas e rotinas definidas para coordenar e (re)configurar suas capacidades na condução do PCTPS. / Radically new technologies only generate returns by their efficient conversion into processes, products and services. However, enterprises need to develop new capabilities and improve the existing ones to become able to the development and commercialization of new products. This thesis presents, in the context of process of technology conversion to products and services, a model for performance measurement through the capabilities evolution and (re)configuration. This kind of evaluation is adequate in the context of radical development projects, as ones occurring in new technology based companies, with distinction to academic spin-off companies. The model was initially composed by a framework that incorporated and attended the promises identified from the literature. This framework was then embodied with tools and practices. To enable the capabilities evaluation, were defined the constructs for measurement of capabilities adjustment and development levels. From these constructs, the metrics for evaluation were proposed. The model was validated by evaluation with specialists, experimental and simulation analysis and usability test in a case. Methods, forms, and indexes were incorporated in a tool to enable the model operationalization. This tool was designed as a multi-criteria decision method that presents a structure for index combining and for report elaboration. The model supports the companies to evaluate their capabilities and identify how to combine them and develop them to create an organizational structure. This evaluation is understood as a guide for policies and routines definition in the process of coordination and (re)configuration of capabilities during the conduction of the new technologies conversion into processes, products and services.

Seit 1998 unterstützt dresden|exists Gründungsinteressierte aus den Dresdner Hochschulen und Forschungseinrichtungen. In dieser Zeit besuchten mehr als 6.800 Studierende die Vorlesungen zu Gründungsthemen und über 2.800 Geschäftsideen wurden an dresden|exists herangetragen. Doch was ist aus den vielen Ideen geworden? Wir haben bei 20 dieser Gründungen konkret nachgefragt. In der Broschüre zum 15. Jubiläum geben Gründer Einblicke in ihre Geschäftskonzepte und teilen einige ihrer Erfahrungen aus der Gründungsphase.

National innovative performance is a key driver for sustainable growth (Pavitt, 1980). National innovative capacity may be improved by fostering industrial Research and Development (R&D), by funding academic research and by effectively supporting university-industry interactions in order to strengthen the linkage between R&D and product development. In a context of growing relevance of external sources of innovation, where the industry, rather than relying on internal R&D, increasingly engages in ‘open innovation’ (Chesbrough, 2006), the role played by universities is crucial. The essays presented in this thesis focus mainly on academic R&D and knowledge transfer mechanisms from the university viewpoint, as opposed to government or industry perspectives. These essays contribute to our understanding of how universities organise themselves to adapt to this changing context. In other words, the thesis looks at the ‘reflexivity’ norm of the system associated with the entrepreneurial university, as established by Etzkowitz (2004); or “a continuing renovation of the internal structure of the university as its relation to industry and government changes, and of industry and government as their relationship to the university is revised”. <p>Universities play a major role in the national innovative capacity of a country as producers and transmitters of new knowledge (see for instance, Adams, 1990; Mansfield, 1991; Klevorick et al. 1995; Zucker et al. 1998; Cohen et al. 2002; Arundel and Geuna, 2004; Guellec and van Pottelsberghe, 2004). While European countries play a leading global role in terms of scientific output, they lag behind in the ability to convert this strength into wealth-generating innovations (this is known as the ‘European paradox’, see for instance Tijssen and van Wijk, 1999; and Dosi et al. 2005). This level of innovation may be improved by different factors; for instance, by fostering an entrepreneurial culture, or by increasing industry’s willingness to develop new products, new processes. One of these factors relies on the notion of an ‘entrepreneurial university’. Universities, in addition to the two traditional missions of research and teaching, foster their third mission of contribution to society, by improving the transfer of knowledge to the industry. New tools and regulations have been established to support universities in this process. Since the early 80’s, academic technology transfer offices (TTOs) have been created, dedicated employees have been trained and hired, incubators for the launch of new academic ventures have been set up, academic or independent pre-seed investment funds have been founded and laws related to the ownerships by university of their invented-patents have been promulgated. <p>But what exactly stands behind the notion of ‘entrepreneurial university’? There exist more different descriptions of a similar concept or of a similar evolution than a general agreed definition. Indeed, "(…) There is high heterogeneity, there is no such thing as a typical university, and there is no typical way to be or become an entrepreneurial university" (Martinelli et al. 2008, p.260). However some similar patterns of what is or should be an entrepreneurial university may be identified.<p>First, there is this notion of a revolution experienced by universities that now have to integrate a third mission of contributing to economic development aside of their traditional academic missions. “(…) But in the most advanced segments of the worldwide university system, a ‘second revolution’ takes off. The entrepreneurial university integrates economic development into the university as an academic function along with teaching and research. It is this ‘capitalisation of knowledge’ that is the heart of a new mission for the university, linking universities to users of knowledge more tightly and establishing the university as an economic actor in its own right” (Etzkowitz, 1998, p.833). <p>This revolution finds its origin in a necessary adaptation of universities to an external changing environment where modern societies put a strong emphasis on knowledge. “The concept of the entrepreneurial university envisions an academic structure and function that is revised through the alignment of economic development with research and teaching as academic missions. The transformation of academia from a ‘secondary’ to a ‘primary’ institution is a heretofore unexpected outcome of the institutional development of modern society (Mills, 1958). In consequence, the knowledge industry in modern societies is no longer a minor affair run by an intellectual elite, an activity that might be considered by pragmatic leaders as expendable; it is a mammoth enterprise on a par with heavy industry, and just as necessary to the country in which it is situated (Graham, 1998, p.129)”, quoted by Etzkowitz et al. (2000, p.329).<p>The notion of an ‘entrepreneurial university’ also exceeds the simple idea of the protection of academic intellectual property by patents owned by universities and their out-licensing as well as the launch of new ventures. It encompasses an overall change of how the university is organised. “In the gruesome and heady world of changing external environments, organizations – including universities – will need to seek opportunities beyond their existing competences (Hamel and Prahalad, 1989, 1994), which suggests the need for an entrepreneurial orientation (Lumpkin and Dess, 1996)”, quoted by Glassman et al. (2003, p.356). This entrepreneurial orientation will only be possible if the overall organisation of the university changes. “An entrepreneurial university, on its own, actively seeks to innovate how it goes about its business. It seeks to work out a substantial shift in organizational character so as to arrive at a more promising posture for the future. Entrepreneurial universities seek to become 'stand-up' universities that are significant actors on their own terms” (Clark, 1998, p.4). <p>The notion of entrepreneurial university also encompasses the concept of academic entrepreneurship in its broad sense. For a university to become entrepreneurial, individual academics also have to adapt and to behave in an entrepreneurial way. This concept is not solely conceived here as the launching of new ventures by academics (a view embraced by Shane, 2004, for instance). It relates more to the view of Stevenson, Roberts and Grousbeck (1989), referenced by Glassman et al. (2003, p.354) or “the process of creating and seizing an opportunity and pursuing it to create something of value regardless of current available resources.”<p>The difficulty facing universities is then to adapt to their external environment while preserving the integrity of their two traditional academic missions. However, some conceive this challenge as precisely an ability that characterise the very intrinsic university’s nature. "The uniqueness of the university,(…) lies in its protean capacity to change its shape and function to suit its temporal and sociopolitical environment while retaining enough continuity to deserve its unchanging name” (Perkin, 1984, p.18). <p>Furthermore, others perceive this challenge as a tension that has always been at the root of the university’s character. “The cherished view of some academics that higher education started out on the Acropolis of scholarship and was desecrated by descent into the Agora of materialistic pursuit led by ungodly commercial interests and scheming public officials and venal academic leaders is just not true for the university systems that have developed at least since 1200 A.D. If anything, higher education started in the Agora, the market place, at the bottom of the hill and ascended to the Acropolis on the top of the hill… Mostly it has lived in tension, at one and the same time at the bottom of the hill, at the top of the hill, and on many paths in between” (Kerr, 1988, p.4; quoted by Glassman, 2003, p.353).<p>Nevertheless, it appears that some institutions, the ones integrating the best their different missions and being the most ‘complete’ in terms of the activities they perform, will be better positioned to overcome this second revolution than other institutions. “Since science-based innovations increasingly have a multidisciplinary character and build on "difficult-to-codify" people-centred interactions, university-based systems of industry science links, which combine basic and applied research with a broader education mission, are seen as enjoying a comparative advantage relative to research institutes” (OECD, 2001 quoted by Debackere and Veugeleers, 2005, p.324). Or as stated by Geuna (1998, p.266), in his analysis of the way the different historical trajectories of European universities are influencing their ability to adapt to the current changing environment, “ (…) the renowned institutions of Cluster IV (pre-war institutions, large in size, with high research output and productivity) are in a strong position both scientifically and politically, and can exercise bargaining power in their relations with government and industry. (…) On the other side, universities in the other two clusters (new postwar universities, characterised by small size, low research output and low research orientation and productivity, whether involved in technological research or in teaching), with very low research grants from government, are pushed to rely more heavily on industrial funding. Being in a weak financial position, they may find themselves in an asymmetric bargaining relationship with industry that they may be unable to manage effectively.”<p>To summarize, one could attempt to define the broad notion of an ‘entrepreneurial university’ as follows. An entrepreneurial university is a university that adapts to the current changing environment that puts a stronger emphasis on knowledge, by properly integrating the third mission or the capitalisation of knowledge aside of its two traditional missions. This adaptation requires a radical change in the way the university is organised. It will require important strategic reorientation from the top but also, and mainly, it will require from the individual academics to better seize new opportunities to generate value (not only financial but also scientific or academic) given scarcer resources. Renowned and complete universities (with teaching, basic and applied research) have an edge over other institutions to overcome this second revolution.<p>This notion of ‘entrepreneurial university’ has drawn criticisms. For example, academics’ interactions with industry could impact negatively on research activities by reorienting fundamental research towards more applied research projects (Cohen and Randazzese, 1996; David, 2000), by restricting academic freedom (Cohen et al. 1994; Blumenthal et al. 1996; Blumenthal et al. 1997), or by potentially reducing scientific productivity (see for instance van Zeebroeck et al. 2008 for a review on this issue). The present work does not address the issue of the impact of increased interactions with the business sector on traditional academic missions nor the question of whether universities should become entrepreneurial or not. Instead, the essays start from the idea that the ‘entrepreneurial university’ notion is part of the intrinsic nature of modern universities, or at least, is a part of its evolution. Industry-university relationships are not a new phenomenon; it can be traced at least to the mid- to late-1800s in Europe and to at least the industrial revolution in the USA (Hall et al. 2001). What is evolving is the nature of such relationships that become more formal. The present analysis starts then from the general observation that some universities (and researchers) are more entrepreneurially-oriented and better accept this mission than others. From that stems the primary research question addressed in this thesis: are there characteristics or conditions leading to a smooth coexistence of traditional and new academic missions inside an entrepreneurial university? And if so, what are they?<p>Existing work on the entrepreneurial university is a nascent but already well developed field of research. The aimed contribution of this thesis is to analyse the topic under three specific but complementary angles. These three perspectives are explored into the four main chapters of this work, structured as follows. Chapter 1 is titled “Turning science into business: A case study of a traditional European research university”. It introduces the topic by investigating the dynamics at play that may explain the propensity of a traditional, research-oriented university to start generate entrepreneurial outputs, while being not full-fledge entrepreneurially organised. Exploring the importance of “new” entrepreneurial outputs, as defined as patents and spin-off companies, compared to other ways of transferring new knowledge to the industry, Chapter 2 reviews the literature on the variety of knowledge transfer mechanisms (KTMs) used in university-industry interactions. It is titled “University-Industry interactions and knowledge transfer mechanisms: a critical survey”. Given scarcer structural funds for academic research and increasing pressure on academics to diversify their activities in terms of being involved in patenting or spin-off launching, Chapter 3 and Chapter 4 investigate the role played by individual characteristics of researchers in attracting competitive, external funding. Chapter 3 presents stylised facts related to external fundraising at ULB and characteristics of researchers who attracted these funds over the period 1998-2008. The empirical analysis on associations between individual characteristics of researchers (intrinsic, scientific and entrepreneurial) and the extent of funds attracted from different sources (national, regional and business) is presented in Chapter 4, titled “The determinants of academic fundraising.” Chapter 5 concludes and suggests ideas for future investigation on this topic. Chapter 6, in appendix of the present work, titled “A note on the drivers of R&D intensity”, is not directly linked to the issue of the entrepreneurial university. It has been included to complement the studied topic and to put in perspective the present work. Academic research and university-industry interactions constitute important drivers of a national R&D and innovation system. Other factors are at play as well. Looking at this issue at the macroeconomic level, Chapter 6 investigates to what extent the industrial structure of a country influences the observed R&D intensity, and hence would bias the well-known country rankings based on aggregate R&D intensity.<p> / Doctorat en Sciences économiques et de gestion / info:eu-repo/semantics/nonPublished

Around the world, knowledge and technology transfer have moved to the forefront of attention in economic, social and industrial policy. As the origins of future development increasingly derives from innovation, attention is paid more and more to non-traditional sources that have the potential to become the basis for creation of new businesses or the catalyser for the rejuvenation of old ones. Among those sources, we find university. These last years, academic patents have been one of the emerging phenomena witnessing the growing evolvement of university in the innovation process. The aim of this doctoral dissertation is to analyse the transfer of technology from university to industry through the analysis of patents. This work pursuits a threefold approach. First, it intends to analyse which characteristics determine the propensity of a university to get involved in technology transfer and more specifically to apply for a patent. Second, it disentangles the underlining value determinants of the patents to decode the value of academic patents and to identify the research processes that are leading to the most valuable inventions. Finally, it investigates the relevancy of academic patenting for innovation in general and wonders if on the long run, such practices could put innovation at risk. / Doctorat en Sciences économiques et de gestion / info:eu-repo/semantics/nonPublished

Due to an intensified climate change discourse, renewable energy technologies find higher attention within the energy system and increasingly compete with traditional energy conversion systems. Electricity is progressively being generated through renewable electricity generation technologies (REGT) which harness naturally existing energy fluxes (wind, tide, heat, sun) and convert it to electricity. High investments are currently being made into well-developed REGT using explored energy sources such as wind, hydro or solar. In order to increase cost- and energy efficiency of REGTs, university research projects are developing new REGTs that harvest underexplored energy sources such as the marine energy source. These capital-intensive marine energy research projects are entering the market through university spin-off firms but are often confronted with funding gaps, for the current or future operations. Capital rich investors could provide these funds but are often investing in well explored energy sources rather than into underexplored but more cost- and energy-efficient energy sources. Utilizing a qualitative, grounded theory-influenced approach and combining empirical material of semi-structured interviews, data from a participant observation of an innovation system workshop attendance and data from continuous meetings with an academic REGT spin-off from Uppsala University, this study investigates 1) the drivers and barriers within the funding ecosystem for academic REGT spin-offs in Sweden, 2) the limited access of high capital to underexplored energy sources on the specific case of the marine energy source and 3) a potential common ground for investors with high capital and academic REGT spin-offs in order to allow an accelerated diffusion of the marine energy source. The results indicate that the physical properties of the underexplored marine source should not be accounted for as driver but rather as the foundation of an academic REGT spin-off. This frame allows to bridge practitioners of both the investment field and the academic field of REGT spin-offs through the degree of utilization. An inversion of relations, where not only entrepreneurs increasingly link their field of study to economy and business, but also investors adapt cross-disciplinary knowledge towards academia and natural sciences via the degree of utilization, could be beneficial for an accelerated diffusion of academic REGTs. Bridging practitioners of both fields through the degree of utilization and other means might together with a full commercial application and proof of marine REGTs reduce the funding gap of academic spin-offs in the marine sector and allow access to investors with high capital.

Made available in DSpace on 2016-04-26T20:20:56Z (GMT). No. of bitstreams: 1 Roberta Bordini Prado.pdf: 744864 bytes, checksum: 4a057d5ffd6e9e5480c3156b6de0d8cc (MD5) Previous issue date: 2012-05-30 / This is a study that aims to research the legal content that establish the legal relationship of the registry of goodwill on the acquisition of equity on a controlled company, and the possibility to depreciate from income tax calculation basis the goodwill registered on the acquisition, when of the amalgamation of the acquired company due to a merger or spin-off. It was analyzed the construction of the legal texts in comparison with the accounting standards currently adopted by the Brazilian accounting system, followed by the recent changes influenced by worldwide modifications on these rules. The premise of a closed, autonomous and independent system of laws was taken in consideration without the existence of dialogism and Intertextuality between the science of law and accounting science. Thus were examined normative tax assumptions in order to compare it with corporate law and accounting records. Since no changes were identified on tax laws on this subject, were analyzed the structures and limits of the possibilities of register, measurement and amortization of the goodwill for tax purposes. Considering the facts and the legal aspects that could justify the possibility to apply the rules related to the amortization of goodwill, it was verified the importance of the theory of evidence to each specific case. Finally, it was analyzed if the main administrative court decisions on the subject that can be related to the discussions here taken / O estudo tem como objetivo a investigação das hipóteses normativas que estabelecem a relação jurídica do registro de ágio no momento da aquisição de participação societária em sociedade controlada ou coligada, bem como a possibilidade de amortização da base de cálculo do imposto sobre a renda do ágio gerado na aquisição em caso de posterior incorporação do patrimônio de sociedade adquirida em virtude de operações societárias de incorporação, fusão ou cisão. Investigou-se a construção das referidas hipóteses normativas frente à mudança de padrões de contabilidade atualmente adotados pelo sistema contábil brasileiro, seguindo-se a tendência mundial dessas alterações, e mudanças legislativas recentes. Partiu-se da premissa do direito como um sistema fechado, autônomo e independente sem se olvidar da existência do dialogismo e da intertextualidade entre a ciência do direito e a ciência contábil. Analisou-se, assim, as hipóteses normativas fiscais de forma comparativa aos preceitos estabelecidos pela legislação societária e os registros contábeis. E, não tendo sido alterada a legislação fiscal sobre o assunto, buscou-se, a partir da análise da estrutura normativa, estabelecer os limites e os contornos das hipóteses que veiculam as possibilidades de registro, mensuração e amortização do ágio para fins fiscais. Considerando-se, ainda, a necessária relação entre os fatos descritos no antecedente das hipóteses normativas e a realidade fática, para o fim de se identificar o fenômeno da subsunção do fato à hipótese normativa descrita, capaz de ensejar a possibilidade de amortização do ágio gerado na aquisição, verificou-se a importância da Teoria das Provas para o deslinde de cada caso concreto. Por fim, analisou-se as principais decisões administrativas sobre o assunto que guardam relação com as conclusões alcançadas nesse estudo

El objeto de este trabajo ha sido el estudio, para el caso del Sistema Universitario Mexicano de la interrelaci��n de la innovaci��n, el emprendimiento y la universidad como elementos indispensables que deben combinarse para el fomento de una cultura emprendedora y de creaci��n de empresas, reforzando as�� la vinculaci��n de las universidades con los ��mbitos productivo, p��blico y social. As��, se trata de profundizar no s��lo en la doctrina y literatura sobre la materia, sino tambi��n en el estudio pormenorizado de las especiales caracter��sticas de la vinculaci��n en el sistema universitario mexicano. La metodolog��a es cuantitativa, a partir de la explotaci��n de la informaci��n recogida, nos ha sido posible mostrar, las caracter��sticas de vinculaci��n comunes al conjunto de las universidades y las caracter��sticas de vinculaci��n espec��ficas de las universidades seg��n su subsistema y su regi��n. En vista de resultados los objetivos y la hip��tesis de la investigaci��n han sido alcanzados. / The purpose of this work was to study the case of the Mexican University System of the interplay of innovation, entrepreneurship and the university as essential elements to be combined to foster an entrepreneurial culture and entrepreneurship, thereby reinforcing linking universities to the productive, public and social. Thus, it is not only deepening the doctrine and literature on the subject, but also in the detailed study of the special characteristics of the relationship in the Mexican University System. The methodology is quantitative, based on the exploitation of the information gathered, we were able to show the bonding characteristics common to all universities and characteristics of specific link universities according to their subsystem and its region. Given the objectives and results of the research hypotheses have been achieved.

In the last years, the Peruvian Tax Court has been considered that a corporate spin off where a company transfers a “neutral” or “negative” equity block does not qualifies as a real spin off, hence it should apply the tax rules as if this operation was a common sale. The author analyzes this criterion, and concludes that spin off where a company transfers a “neutral” or “negative” equity block, constitutes a real spin off. As a consequence, it must apply the special tax rules established for the corporate spin off. / En los últimos años, el Tribunal Fiscal Peruano ha considerado que las reorganizaciones societarias en donde se segreguen bloques patrimoniales negativos/neutros no son verdaderas reorganizaciones societarias para efectos tributarios, y por consiguiente se les aplicaría las normas tributarias previstas para las enajenaciones comunes. El autor analiza dichos pronunciamientos, concluyendo que las reorganizaciones societarias con bloques patrimoniales negativos/neutros, sí constituyen verdaderas reorganizaciones societarias para todos los efectos y por ende, les son aplicables las normas tributarias especiales previstas para reorganizaciones societarias.