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2.2. Tax Consequence of Contributions

The following are the main tax consequences of contributions:

(i) Contributions in kind (both of movable and immovable property) are not taxes with VAT, provided that, in the case of immovable property, the transfer or commercialization of real estate is no part of the ordinary course of business of the company receiving the contribution.

(ii) The creation, emission and transfer of shares are not subject to VAT.

(iii) When contributing fixed assets, the value of the contribution must be equal to the carrying value of the assets. Any difference between this value and the former will be subject to capital gains tax.