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A Spanish company asked whether dividend distributions to its Swedish parent were exempt from IRNR under article 14.1 h) of the TRLIRNR, given that the parent is now part of an American group. The DGT confirmed the exemption, as the Swedish parent has legitimate economic reasons and was not established for abuse of the regime.
The exemption applies when a parent company has genuine economic justifications and was not created to exploit the tax regime.
The tax team reviews your specific situation.
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