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A company is inquiring whether dividends received from its subsidiary, registered in the Canary Islands Special Zone (ZEC), are eligible for the double taxation exemption. The DGT rules that this is possible provided the requirements of Article 21 of the Corporate Income Tax Act are met.
Question raised: Whether the dividends received by the consulting entity from its subsidiary D are eligible for the exemption to avoid double taxation set forth in Article 21 of Law 27/2014, of November 27, on Corporate Income Tax.
Los dividendos distribuidos por una entidad del ZEC tienen derecho a la exención prevista en el artículo 21 de la LIS. El hecho de que la entidad participada tribute a tipos bonificados propios de la ZEC no impide la aplicación de la exención, siempre que se cumplan los requisitos de participación y de imposición mínima establecidos en la norma.
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