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A parent company has queried whether it can include in its consolidated tax base the negative income from a subsidiary being dissolved through merger or liquidation. The Directorate General for Taxes (DGT) has ruled that the operation generates negative income for the parent company, based on the difference between the tax value of the holding and the assets received; this amount must be reduced by any negative tax bases of the subsidiary that have already been offset within the group.
Cuestión planteada 1. Si en el supuesto de fusión no amparada en el régimen especial de neutralidad fiscal, la sociedad X podrá integrar en la base imponible consolidada las rentas negativas que se pongan de manifiesto con ocasión de la referida operación, calculadas conforme a lo señalado en el artículo 15.7 del texto refundido de la Ley del Impuesto sobre Sociedades.
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