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V2528-14 ·29 September 2014 ·consulta-vinculante Medium impact
Tax

Requirements for exemption from dividend and capital gains tax for non-resident entities

A Spanish company asks whether it can apply the exemption under Article 21 of the TRLIS to dividends and capital gains from a foreign entity (H), whose profits may indirectly arise from other subsidiaries. The DGT explains that exemption is possible if the percentage ownership, foreign tax liability, and the profits derive from commercial activities are met.

In 6 key points

How it affects those involved

Non-resident entities may benefit from tax exemption on dividends and capital gains if their profits stem from commercial activities and meet specific ownership and tax conditions.

Lifecycle

2014-09-29PublishedPublished 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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