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A taxpayer seeks to dissolve a Gibraltar-based company that holds shares in a Spanish company owning real estate. The DGT rules that the dissolution will only be subject to tax on corporate transactions if the foreign company effectively conducts business operations in Spain.
This ruling clarifies the tax implications for the dissolution of foreign entities, establishing that the presence of assets or shares in Spain is insufficient to trigger tax on corporate transactions unless there is actual business activity within the country.
The tax team reviews your specific situation.
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