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Una sociedad consulta si la transmisión de su participación en una entidad vinculada puede acogerse a la exención del artículo 21.3 de la LIS antes de una dilución de su cuota. La DGT señala que la fecha de la transmisión para cumplir los requisitos de exención dependerá de cuándo se produzca la baja contable del activo financiero.
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