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A Spanish company (A) asks whether it can apply the exemption under Article 21 of the TRLIS to the profit from the sale of its share in an ETVE (E), which holds direct and indirect shares in non-resident entities. The DGT confirms that the exemption can be applied to the portion of the profit attributable to shares in non-resident entities that meet the conditions of Article 21, whether the share is direct or indirect.
The tax team reviews your specific situation.
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