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A holding company engaged solely in holding and managing shares of at least 5%, with no staff or office, seeks confirmation of its status as a patrimonial entity and whether it qualifies for the exemption under article 21 of the LIS on dividends and capital gains from share transfers. The administrator carries out management in return for remuneration.
The ruling clarifies the conditions under which a holding company without employees or premises may be considered a patrimonial entity and qualify for the exemption from dividend and share transfer gains tax under article 21 of the LIS.
The tax team reviews your specific situation.
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