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A query was raised regarding whether the 75% participation requirement for the tax consolidation regime should be calculated based on issued shares or shares in circulation. The DGT clarifies that, in the event of acquiring treasury shares, the percentage is determined based on the shares in circulation.
Question posed: Method for calculating the participation percentage under Article 58.2.b) of the Corporate Income Tax Law, specifically, whether it must be calculated based on issued shares or outstanding shares.
To determine whether an entity is a parent company and meets the 75% share capital participation requirement, the percentage of outstanding shares must be considered. In the case analyzed, the acquisition of treasury shares modified the parent company's participation percentage regarding the outstanding shares.
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