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The DGT clarifies that dividend exemption depends on whether the held entities function as holding companies.
Question raised
If the investee entities derive more than 70% of their income from dividends or capital income, they are considered holdings, and the applicant is required to meet the minimum participation percentage and the holding period requirements also in the indirectly held entities. If they do not exceed that 70% income threshold, the exemption applies if the direct participation requirements are met. The indirect participation requirement shall not be required if the dividends have been included in the taxable base of the indirectly held entity without applying exemptions or deductions.
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