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A company has requested clarification on how to apply the deduction provided for in the twenty-third transitional provision of the Corporate Income Tax (CIT) Act when receiving dividends corresponding to the premium paid on the acquisition of shares. The Directorate General of Taxes (DGT) clarifies that the deduction applies to the dividend that is not included in the taxable base and that it may be applied to the tax group's gross tax liability.
Cuestión planteada
Para aplicar la deducción de la DT 23ª de la LIS, se debe probar que el importe equivalente al dividendo se integró en la base imponible del IS o del IRPF del transmitente. Si la prueba es parcial, como ocurre al aplicar coeficientes de abatimiento en el IRPF, la deducción se aplicará proporcionalmente. El dividendo que corresponde al sobreprecio no se integra en la base imponible individual de la entidad, pero la deducción resultante puede aplicarse en la cuota íntegra del grupo fiscal.
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