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The taxpayer inquired whether they could apply for the exemption on holdings in companies under the Special Tax Regime (STM) while owning the entity indirectly through QQI. The Directorate General for Taxes (DGT) ruled that indirect ownership cannot be counted towards the STM exemption and that the requirements for activity, ownership, and management must be met separately for each entity.
This ruling clarifies that indirect ownership does not satisfy the requirements for the Special Tax Regime exemption, necessitating direct compliance with activity and management criteria at each level of the corporate structure.
The tax team reviews your specific situation.
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