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A query was raised regarding whether the transfer of a shareholding in an entity qualifies for Corporation Tax exemption and how the status of a holding company affects this. The DGT clarifies that, if the entity is a holding company, only the portion of income corresponding to undistributed profits generated during the holding period is exempt.
Cuestión planteada Si la entidad Y tiene la consideración de entidad patrimonial a los efectos del artículo 5 y del artículo 21.5.a) de la Ley del Impuesto sobre Sociedades
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