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V3561-15 ·18 November 2015 ·consulta-vinculante Medium impact
FISCAL

Dividends from a Dutch entity exempt if reserves from prior transfer from Spanish subsidiary

The consultant asks whether dividends paid by a Dutch company from reserves obtained through the sale of a Spanish subsidiary are exempt. The DGT confirms that exemption under Article 21 of the LIS is possible if participation and residency requirements are met.

In 6 key points

How it affects those involved

The exemption applies to dividends from Dutch entities when reserves originate from the sale of a Spanish subsidiary, provided participation and residency conditions are satisfied.

Lifecycle

2015-11-18PublishedPublished 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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