Circulars n.14 / 2009 - The requirement of commerciality in the Participation Exemption

The requirement of commerciality in the Participation Exemption

This circular intends to provide clarifications regarding the existence of the commerciality requirement in order to benefit from the Pex legislation in certain cases, following some resolutions of the Revenue Agency and the response to parliamentary question no.5-01695 of 29 July 2009 .

Topics index

1. "Pex" regime
2. Commerciality in Pex according to the standard
3. Commerciality in Pex according to the Revenue Agency
   1. Resolution no. 152 / E of 15 December 2004 - Real estate management
   2. Resolution no. 163 / E of 25 November 2005 - Rent of the only company
   3. Resolution no. 165 / E of 25 November 2005 - Management of debt / credit positions
   4. Resolution no. 323 / E of 9 November 2007 - Hotel under construction
   5. Resolution no. 226 / E of 18 August 2009 - Passive Income
4. The answer to the parliamentary question - Start Up

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