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V3348-14 ·18 December 2014 ·consulta-vinculante Medium impact
Tax

Shareholders of an ETVE may apply the special regime for foreign holding entities

The query asks whether shareholders of an entity may apply the regime under Article 118 of the TRLIS regarding income from non-resident entities held through a subholding (B1). The DGT confirms that this is possible if the subholding is a purely instrumental entity whose income arises from non-resident entities meeting the exemption conditions under Article 21.

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2014-12-18PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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