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A group company sells a property to a bank, which then leases it via financial lease to another company within the same group. The DGT has ruled that, as this is an internal transaction between group entities, the gain from the sale must be eliminated when calculating the consolidated tax base.
This ruling ensures that intra-group transactions do not artificially inflate the consolidated tax base, reinforcing the principle of economic reality in tax consolidation.
The tax team reviews your specific situation.
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