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The query asks whether dividends paid from the accumulated reserves of an entity B would be exempt in Spain. The DGT rules that the exemption applies provided that the requirements regarding shareholding and the taxation of subsidiaries abroad are met.
Question posed: Whether dividends charged to reserves accumulated until December 31, 2014, which entity B intends to distribute to the consulting entity, would be exempt from taxation in Spain, in accordance with the provisions of Article 21.1 of Law 27/2014, of November 27, on Corporate Income Tax.
La exención del artículo 21.1 de la LIS es aplicable si se cumple el porcentaje de participación mínimo y la tenencia ininterrumpida. En caso de que la entidad participada obtenga ingresos mayoritariamente de dividendos, la exención requiere que la participación indirecta en esas entidades también cumpla los requisitos. Para filiales no residentes, estas deben residir en países con convenio de intercambio de información o estar sujetas a un impuesto análogo de al menos el 10%, sin residir en paraísos fiscales.
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