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A query was raised regarding whether the reduction under Article 23 of the CIT Act for the transfer of intangibles applies when the transaction occurs between entities within the same tax consolidation group. The DGT clarifies that, as the express prohibition found in the previous wording no longer exists, these transactions are governed by tax consolidation rules, and the reduction shall apply as the elimination of said internal transaction is recognised.
This ruling clarifies the applicability of tax reductions for intangible transfers within tax groups, ensuring alignment with tax consolidation principles and the timing of profit elimination.
The tax team reviews your specific situation.
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