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A company queried whether the transfer of 100% of the shares in a subsidiary could qualify for the Corporate Tax exemption. The DGT clarifies that if the subsidiary is a holding company, the exemption only applies to the portion of income corresponding to an increase in undistributed profits generated during the period of ownership.
This ruling limits the scope of the participation exemption for holding companies, ensuring that only the growth in undistributed profits is exempt, rather than the entire proceeds from the share transfer.
The tax team reviews your specific situation.
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