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A company has requested clarification on how to apply the deduction provided for in the twenty-third transitional provision of the Corporate Income Tax (CIT) Act when receiving dividends corresponding to the premium paid on the acquisition of shares. The Directorate General of Taxes (DGT) clarifies that the deduction applies to the dividend that is not included in the taxable base and that it may be applied to the tax group's gross tax liability.
This ruling clarifies the tax treatment of dividends related to share premiums within tax groups, confirming that the double taxation deduction can be applied to the group's tax liability rather than being restricted to individual entities.
The tax team reviews your specific situation.
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