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A consulting entity asks whether it can apply the exemption under Article 21 of the Corporate Income Tax Act regarding the sale of shares in two companies. The Directorate General for Taxes (DGT) responds that this is possible provided the requirements for shareholding percentage and holding period are met, and as long as the companies are not investment entities.
Question posed: Whether the exemption provided for in Article 21 of Law 27/2014, of November 27, on Corporate Income Tax could be applied to a potential sale of the interest in entities S and R by the consulting entity.
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