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A consulting firm has queried whether it can apply the reduction under Article 23 of the TRLIS to income derived from the licensing of its methodology (know-how) when the contract also encompasses technical assistance. The DGT has ruled that this is possible, provided that the consideration for each concept is expressly differentiated within the contract.
Companies providing both know-how and technical assistance must ensure their contracts clearly separate the fees for each service to benefit from the specific tax reduction on know-how income.
The tax team reviews your specific situation.
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