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A taxpayer assigns a credit right from an agricultural cooperative in insolvency proceedings to a bank at a price lower than its nominal value. The Directorate General for Taxes (DGT) determines that this transaction constitutes a capital loss.
La transmisión de un derecho de crédito mediante un contrato de cesión con una entidad bancaria supone una alteración en la composición del patrimonio. Se produce una pérdida patrimonial por la diferencia entre el valor del derecho de crédito y el importe obtenido por la cesión.
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