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The DGT asks whether a cooperative and its associated entities are linked and how their operations should be valued. It states that if ownership is 25% or higher, a link exists and operations must be adjusted to market value.
Question raised
If the cooperative member entities hold a participation equal to or greater than 25% in the consulting entity, both are considered related parties pursuant to Article 18.2 of the LIS. In this case, transactions between them must be valued at their market value using the methods provided for in Article 18.4 of the LIS. The choice of valuation method is at the discretion of the entities, subject to the verification powers of the Administration.
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