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A public limited company distributing dividends to two legal entities holding more than 5% of capital for over a year is not required to withhold tax under LIS Article 21.1, provided the conditions are met. However, even without a withholding obligation, the paying entity must file Model 123 with a negative declaration if no other taxable income has been paid during the period.
Companies with significant cross-shareholdings may avoid withholding tax on dividends, but must still submit a negative Model 123 declaration to ensure compliance with tax reporting requirements.
The tax team reviews your specific situation.
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