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V2217-14 ·8 August 2014 ·consulta-vinculante Medium impact
Tax

Economic reasons for relocating a business unit to Switzerland may qualify for dividend exemption

A company asks whether the reasons for moving its Travel Retail unit from Spain to Switzerland constitute valid economic grounds for applying the international double taxation exemption. The DGT states that the stated reasons may be considered valid, although their truth is a factual issue that must be proven.

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2014-08-08PublishedPublished 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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