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A query was raised regarding whether dividend distributions from a company that should have been taxed as a patrimonial company are exempt from the shareholders' Personal Income Tax (IRPF). The Directorate General for Taxes (DGT) ruled that, to prevent double taxation, such dividends are not included in the taxable income for the period.
Cuestión planteada Si el reparto de dicho dividendo estaría exento en el IRPF de los socios, de acuerdo con el régimen aplicable a las sociedades patrimoniales, dado que en opinión de los consultantes se trata de una cantidad que fue considerada inicialmente gasto por Impuesto sobre Sociedades, minorando el beneficio distribuible de la entidad correspondiente al ejercicio 2006.
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