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A consultant asks whether investment in a European Capital Risk Fund (FCRE) targeting real estate allows IP exemption. The DGT clarifies how fund assets must be accounted for to determine if it constitutes an economic activity or a wealth management operation.
Cuestión planteada En relación con la inversión por la sociedad L en el FCRE S.A., a efectos de aplicar la exención prevista en el artículo 4.Ocho. Dos de la Ley 19/1991, del Impuesto sobre el Patrimonio, por parte del consultante, se plantean las siguientes cuestiones:
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