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An asset management company has enquired whether it can be held subsidiarily liable for tax debts related to properties acquired before it held ownership. The Directorate General for Taxes (DGT) has ruled that banking resolution regulations exclude such liability regarding the transferred assets.
Cuestión planteada ¿Se puede derivar al consultante por la responsabilidad subsidiaria que prevé el artículo 79 de la Ley 58/2003, de 17 de diciembre, General Tributaria (BOE de 18 de diciembre) por los inmuebles que hubiera adquirido en relación a las deudas tributarias que se hubieran devengado con anterioridad a dicha adquisición?
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