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The taxpayer asks how transactions involving the transfer of credit rights should be included when calculating their VAT deduction pro rata. The DGT rules that only the capital gain obtained shall be accounted for, provided it is positive.
This ruling clarifies the calculation of the VAT deduction pro rata for entities involved in credit transfers, ensuring that only the actual profit (capital gain) affects the denominator, rather than the total transaction value.
The tax team reviews your specific situation.
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