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V2436-22 ·25 November 2022 ·consulta-vinculante Medium impact
Tax

Foreign tax excess over treaty amount not deductible

The query concerns the application of the international double taxation deduction when foreign tax paid exceeds the amount agreed in a treaty. The DGT responds that the excess is not deductible under Article 31 of the LIS and cannot be considered a deductible expense if there is no economic activity abroad.

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2022-11-25PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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