- The sale of shares by a holding company does not count towards the prorated calculation as it is a one-off operation unrelated to the company’s economic activity.
- The holding company was found to have two distinct activities: providing management support services to group companies and engaging in financial activities such as loans and share transactions.
- The exclusion of certain financial operations from the prorated calculation is intended to avoid distortions and only include activities that reflect the taxpayer’s professional activity.
- The sale of shares in this case was a one-time, non-recurring event that was not a regular part of the company’s business activities.
- The sale was not directly related to the company’s financial activities and did not involve a significant use of resources, so it should not be included in the prorated calculation according to the law.
Source: audiconsultores-etlglobal.com
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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