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A dominant company in a fiscal consolidation group asks whether losses from the dissolution of two subsidiaries are deductible. The DGT confirms that negative income is deductible under art. 21.8 LIS as it is not a restructuring. However, the loss from a subsidiary incorporated in the group must first be reduced by negative taxable bases generated and compensated within the group, and both losses must additionally be reduced by exempt dividends received in the ten years prior to dissolution.
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