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A Spanish company asks how to calculate the double taxation deduction for interest earned in Brazil, exempt from Brazilian withholding. The DGT states that, under the Brazil agreement, such interest is deemed to have been taxed at 20% for double taxation purposes.
Question raised: For the purposes of applying the deduction under Article 31 of the LIS, what would be the base and the deduction percentage and, where applicable, the limit thereof?
For the deduction under Article 31 of the LIS, the lesser of the amount actually paid abroad or the tax liability that would correspond in Spain shall be deducted. Notwithstanding, as a Double Taxation Convention exists, the deduction may not exceed the tax corresponding to said Convention. In the case of interest between Spain and Brazil, it shall be considered to have been taxed at 20% for the purposes of the elimination of double taxation, thereby limiting the deduction to that percentage of the amount of the interest.
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