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A Spanish company owning one-third of a Moroccan entity seeks advice on the treatment of capital repayment and dividend distribution. The DGT examines the application of the Double Taxation Agreement and the Corporate Tax and IRNR regulations.
Question posed: What is the tax treatment in both Spain and Morocco regarding the refund of contributions and the distribution of profits.
For dividends, the Convention limits taxation in Morocco to 10% based on capital ownership, allowing Spain to eliminate double taxation. In the event of a capital reduction, gains are only taxed in Spain. Regarding Corporate Income Tax, the refund of contributions includes in the tax base the excess of the fair market value over the book value. Dividends may be exempt if the requirements of participation, business activity, and taxation abroad are met.
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