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V0818-15 13 March 2015 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · renta mundial

Spanish residents must pay tax on worldwide dividends and can claim international double taxation relief

A Spanish tax resident enquires about the taxation of dividends from Spanish and foreign companies received in an Andorra account. The DGT confirms that such individuals must pay tax on their worldwide income and explains how to apply the international double taxation relief.

The question raised

Taxation in the Personal Income Tax of the aforementioned dividends.

The DGT's ruling

The taxpayer must be taxed in Spain on the totality of their income, regardless of its origin or the residence of the payer. Dividends are included in the savings tax base for their full amount. For dividends from a foreign source, the corresponding Double Taxation Convention shall apply, and the tax paid abroad may be deducted pursuant to Article 80 of the Personal Income Tax Law (LIRPF). The deductible amount shall not exceed the amount corresponding to the tax liability in the foreign country according to the Convention.

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