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A company has requested a ruling on whether it can apply the deduction under Article 30.3 of the CIT Act when transferring its 20% stake in an entity through a capital reduction for the purpose of cancelling shares. The DGT has ruled that it is possible to apply the deduction to the undistributed profits corresponding to the reserves applied to said cancellation.
Cuestión planteada 1) Si la entidad consultante puede aplicar la deducción para evitar la doble imposición del artículo 30.3 del TRLIS sobre la renta obtenida con motivo de la operación por la cual transmitirá su participación del 20% en el capital social de A.
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