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A taxpayer inquired whether payments made to a third party for the sale of a taxi licence could be considered part of the lower transfer value. The Directorate General for Taxes (DGT) ruled that such costs are deductible, provided they are paid by the transferor and are properly documented.
Cuestión planteada Si dicho pago puede considerarse menor valor de transmisión.
El valor de transmisión es el importe real de la enajenación, del cual se deducen los gastos y tributos satisfechos por el transmitente. El gasto de intermediación puede deducirse para determinar el valor de transmisión de la licencia, siempre que se cumpla el requisito de estar convenientemente justificado.
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