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A non-resident enquires about purchasing a mortgaged property to rent it to a tourism company. The DGT clarifies that there is no passive party investment because the buyer is not a businessperson at the time of acquisition and no permanent establishment exists without own means to manage the rental.
The ruling clarifies that passive party investment and permanent establishment requirements do not apply when the buyer is not an entrepreneur or professional and lacks independent means to manage rental activities.
The tax team reviews your specific situation.
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