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Un contribuyente residente en España consulta si puede deducir en su IRPF de 2020 un pago a cuenta realizado en Italia en 2016 por la futura venta de participaciones de una sociedad italiana. La DGT responde que no procede la deducción por doble imposición porque, según el Convenio, Italia no tiene potestad para gravar esa ganancia.
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