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V0416-18 ·19 February 2018 ·consulta-vinculante Medium impact
Tax

Negative tax bases may be offset if the acquired entity held a stake of 25% or more

A company enquired whether the sale of shares between linked companies within the same group prevented the offsetting of negative tax bases. The DGT ruled that the limitation under Article 26.4 of the Corporate Income Tax Act does not apply if the previous holding was 25% or higher.

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2018-02-19PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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