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The European Investment Fund (FEI), a subsidiary of the European Investment Bank, asks whether its proposed capital reduction with return of contributions in Spanish entities may be exempt from ITPAJD. The DGT concludes that the exemption under Article 3 of the EU Protocol on privileges and immunities applies only to indirect taxes on purchases of goods or services for official use, which does not apply in the case of capital reduction. The subjective exemption under Article 45.1.a) TRLITPAJD also does not apply, as the Protocol does not equate the FEI's regime with that of the State.
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