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MEDIUM
FISCAL

Dividend exemption thresholds and indirect participation rules

V0654-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V0654-25
Published
10 Apr 2025

Summary

A Spanish holding company asks whether it can benefit from dividend exemption on its shareholding in a French company (A), which in turn holds another company (B). The DGT states that if dividend and capital income from company A do not exceed 70% of its consolidated income, there is no need to assess indirect participation in A's subsidiaries.

In 6 key points

Lifecycle

2025-04-10PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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