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The Spanish company T owns 96% of Chilean company C, which holds operating subsidiaries in Chile from which it receives dividends fully exempt in Chile. The DGT concludes that no international transparency tax (art. 100 LIS) applies because, if the dividends had been received in Spain, they would have been exempt under art. 21 LIS with a 5% management cost reduction, meaning Chilean taxation is not lower than the Spanish rate.
The tax team reviews your specific situation.
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