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A company asks whether positive income from a partner separation in a held entity may benefit from the exemption provided in Corporate Tax. The DGT clarifies that the exemption applies if participation and foreign taxation conditions are met.
Question raised 1. Application of the exemption provided for in Article 21.3 of the Corporate Income Tax Law to the positive taxable income potentially generated in the separation operation for the applicant. The separation operation could generate positive income due to the difference, if applicable, between the market value of the assets received as a result of the separation and the tax acquisition cost of the interest in company L.
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