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V0510-15 ·9 February 2015 ·consulta-vinculante Medium impact
Tax

Reduction for know-how transfer in franchises may apply if consideration is clearly identified

A hamburger franchise company has enquired whether it can apply the 40% reduction to royalties for the transfer of know-how. The DGT has ruled that this is possible, provided that the consideration for the know-how is distinguished from other services and the requirements of Article 23 of the Corporate Tax Act (LIS) are met.

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2015-02-09PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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