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The taxpayer asks whether converting a SICAV into a limited company (SL) triggers Article 27.2 d) of the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) rules that it does, as the change in tax rate and legal regime necessitates closing the tax period and applying special rules for income from assets.
Companies undergoing this transformation must prepare for the mandatory closure of their tax period and the application of specific tax rules regarding asset income.
The tax team reviews your specific situation.
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