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An entity asked whether it could claim the corporate income tax exemption on the capital gain from the sale of shares in company X. The DGT replied that this is possible if the percentage of ownership and residency requirements of the holding company are met, noting a possible limitation if company X is a patrimonial entity.
Cuestión planteada Si procedería aplicar la exención establecida en el artículo 21 de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades, en la plusvalía obtenida en la transmisión de las participaciones de la entidad X.
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