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The query examines whether a company carries out economic activity when it subcontracts the necessary means, and how this affects the exemption on the transfer of shares. The DGT determines that if the entity is classified as a holding company during certain periods, the exemption only applies to the portion of income that does not correspond to undistributed profits generated during those periods.
This ruling clarifies the distinction between active companies and holding companies for tax purposes, limiting the tax benefits available when transferring shares if the entity's activity is deemed purely patrimonial during certain periods.
The tax team reviews your specific situation.
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