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The taxpayer asks whether the double taxation deduction can be applied when selling 18.20% of its holdings in an entity and how to determine the base. The DGT clarifies that the deduction is applicable to the net increase in undistributed profits and establishes the rules for calculating the base according to the nature of the transaction.
Question raised 1. Regarding the sale of 18.20% of the social shares of entity A to the other partner, whether the double taxation deduction may be applied to correct capital gains of domestic source and how to determine the deduction base.
In the transfer of securities representing capital, the deduction shall be the tax rate applied to the net increase in undistributed profits generated during the holding period, or the amount of the computed income if this is lower. For the acquisition of treasury shares for amortization purposes, the base shall be the reserves allocated for said amortization, reduced by the capital transferred to reserves previously. The deduction shall be 100% if the holding is equal to or greater than 5% and has been held uninterruptedly during the year prior to the transfer.
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