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A query was raised regarding whether dividend distributions charged against reserves in favour of holding companies are exempt from Corporate Tax. The DGT indicates that the exemption may apply provided that the requirements for shareholding and other statutory conditions are met.
Question raised In relation to the distribution of dividends from reserves, whether it is considered that the distribution of dividends from reserves of entity A, which will be received by the holding companies to which the shares previously held by natural persons PF1, PF2, and PF3 were sold/contributed, constitute accounting income entitled to the exemption provided for in Article 21 of Law 27/2014, of November 27, on Corporate Income Tax.
Se puede aplicar la exención de dividendos del artículo 21.1 de la LIS siempre que se cumplan los requisitos de porcentaje de participación mínima del 5% o valor de adquisición superior a 20 millones de euros, la tenencia ininterrumpida y los requisitos para entidades no residentes si procediera. Además, no existirá obligación de practicar retención sobre dichos dividendos exentos.
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