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A Spanish company asked whether dividends from its fully owned Romanian subsidiary were tax-exempt. The DGT confirms that they are, provided the requirements for ownership and double taxation treaty are met.
Question posed: Whether the Spanish company meets the requirements of Article 22 of the Corporate Income Tax Law, considering that it operates in Romania through a permanent establishment and, therefore, the dividends it is to receive are exempt pursuant to Article 21 of the same Law.
In order for dividends from a non-resident entity to be exempt, a holding of at least 5% must be maintained uninterruptedly during the year preceding the distribution. Furthermore, the participated entity must have been subject to a foreign tax of an analogous nature with a nominal rate of at least 10%. This taxation requirement is deemed to be met if the entity resides in a country with which Spain has a double taxation treaty that includes an exchange of information clause.
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