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V1121-15 13 April 2015 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · dividendos

Brazilian dividends exempt in Spain but count for other income tax rates

A Spanish resident asks whether interest from a loan used to invest in a Brazilian company can be deducted and how Brazilian dividends are taxed. The DGT responds that dividends are exempt in Spain under the Brazil-Spain double taxation treaty, but are used to calculate the tax rate on other types of income, and that loan interest is not deductible.

The question raised

Taxation of the dividend obtained, possibility of deducting interest on loans received. Deductibility of the tax paid in Brazil. Legal viability of obtaining the stated loan and the tax obligations linked thereto. Legal requirements for the repatriation of funds.

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