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V0158-15 ·19 January 2015 ·consulta-vinculante Medium impact
Tax

Deduction for double taxation on dividends possible even if transferor is a non-resident

A consulting company asks whether the internal double taxation deduction can be applied to dividends relating to a premium paid when acquiring a share, where previous transferors included a non-resident entity. The DGT responds that to avoid economic double taxation, the rule must include non-residents who have been taxed in Spain through transfer.

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2015-01-19PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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