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An entity holding 50% of company A, which in turn holds 10% in B and 5% in C, seeks to transfer its share in A in a year when A exceeds 70% of dividend income. Since G meets the minimum indirect shareholding threshold of 5% only for B (5% indirect shareholding) and not for C (2.5% indirect shareholding), exemption under article 21.3 LIS applies only to the portion of capital gain attributable to B. The DGT does not address the 2023 exercise as it involves future facts at the time of the inquiry.
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