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A company requested guidance on applying double taxation relief to the sale of shares using the instalment sale method. The DGT ruled that income recognised in subsequent years will follow the tax regime in force at the time of the transaction.
Cuestión planteada En el supuesto de que la entidad consultante se acogiera a la opción de operaciones a plazo establecida en el artículo 19.4 del texto refundido de la Ley del Impuesto sobre Sociedades, cuál sería el régimen de eliminación de la doble imposición aplicable en los períodos impositivos 2014, 2015 y siguientes.
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