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A query is made as to whether dividends from entity C, acting as a holding company, are exempt from Corporate Income Tax for new investors. The DGT responds that, as part of a group with consolidated accounts, it is sufficient for the shareholding in entity C to exceed 20 million euros.
Question posed: Whether the dividends distributed by entity C to its new investors will be entitled to the exemption provided for in Article 21 of the Corporate Income Tax Law and whether there will be an obligation to withhold tax in respect thereof.
To access the exemption under Article 21.1 of the LIS for holding companies, the requirement of significant shareholding must be met. If the investee entity receives more than 70% of its income from dividends or capital gains, an analysis of the 5% indirect shareholding is required. However, if the subsidiaries are part of the same group with consolidated annual accounts, it is not necessary to respect the minimum 5% threshold at indirect levels, as a shareholding of 20 million euros in the direct entity is sufficient.
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