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V1954-15 ·19 June 2015 ·consulta-vinculante Medium impact
Tax

Negative profits from intra-group share transfers deferred until exit or transfer to third parties

The query asks when negative profits from share transfers causing a company's exit from a fiscal group should be included. The DGT responds that negative profits are not included in the transfer period when shares are transferred between group entities, but only when shares are transferred to third parties outside the group or when the entity ceases to belong to the group.

In 6 key points

Lifecycle

2015-06-19PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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