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A venture capital fund proposes to sell a 24.23% stake in an entity to the issuer itself in order to reduce its share capital. The query asks whether this sale operation is subject to withholding tax under Corporate Income Tax.
Cuestión planteada Si está sujeta a retención la operación de venta de participaciones de A por parte del fondo de capital riesgo.
Las rentas derivadas de la transmisión de participaciones en el capital o en los fondos propios de una entidad no están sujetas a retención. El fondo de capital riesgo es contribuyente del Impuesto sobre Sociedades, pero la operación no encaja en los supuestos de retención previstos reglamentariamente.
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