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A company has requested a ruling on whether the indirect participation of a family group in an entity should be considered when applying the limitation on the offsetting of tax loss carryforwards. The DGT has stated it cannot issue a ruling as it is unable to determine whether a relationship exists between the shareholders and the entity.
Cuestión planteada Si, a efectos de verificar la concurrencia o no de la circunstancia prevista en la letra b) del artículo 26.4 de la LIS, la participación indirecta que los socios de F (grupo familiar) ostentaban en A, a la conclusión del ejercicio 2013, por su participación directa en E, debe o no tomarse en consideración.
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