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The taxpayer asks whether negative extra-accounting adjustments can be applied to amortise intangible assets after transferring 31% of their capital. The DGT rules that, once the transfer of the interest is proven, adjustments of the opposite sign may be made in proportion to the percentage transferred.
This ruling clarifies the tax treatment of intangible assets following a partial divestment, allowing for proportional tax adjustments to reflect the change in ownership.
The tax team reviews your specific situation.
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