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V0896-18 ·6 April 2018 ·consulta-vinculante Medium impact
FISCAL

Transfer of substantial share in Spanish company taxed in Spain under IRNR

A French resident enquires about the taxation of the sale of a 45% share in a Spanish company. The DGT determines that, as it is a substantial share, the gain is taxable in Spain pursuant to the double taxation treaty with France.

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2018-04-06PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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