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A taxpayer has requested clarification on how to value their holdings in three companies to determine the applicability of the exit tax. The DGT clarifies that if the combined limit of 4 million euros is not exceeded, tax is only due if the market value in each entity where the holding exceeds 25% is more than one million euros.
Cuestión planteada Conocer cómo se aplicaría la valoración para el "exit tax".
Si el valor de mercado conjunto de las participaciones no excede de 4.000.000 de euros, el impuesto solo se aplica a aquellas entidades donde la participación sea superior al 25% y el valor de mercado de dichas participaciones exceda de 1.000.000 de euros. En el caso planteado, si el valor de las participaciones en cada una de las tres sociedades no supera el millón de euros, no resulta de aplicación el artículo 95 bis de la LIRPF.
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