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A Spanish company has requested a ruling on whether dividends paid out of reserves from a Swiss entity (B) are exempt from taxation. The DGT states that the exemption applies if the requirements of Article 21 of the Corporate Tax Act are met, including the existence of a double taxation treaty with an exchange of information agreement.
Cuestión planteada Si los dividendos con cargo a reservas en el período 2000 a 2014 que B se plantea distribuir en el ejercicio 2015 estarían exentos de tributación en España, con arreglo a lo dispuesto en el artículo 21 de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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