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V4903-16 ·11 November 2016 ·consulta-vinculante Medium impact
Tax

Shares lent out by a subsidiary count towards the parent company's indirect holding if Art. 21.2.3º LIS requirements are met

A company has requested a ruling on whether shares of a subsidiary that have been lent to a financial institution count towards determining its indirect holding in a third company for the purposes of the dividend exemption. The DGT has ruled that they do count, provided the requirements of Article 21.2.3º of the Corporate Income Tax Act (LIS) are satisfied.

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2016-11-11PublishedPublished 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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