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An entity inquired whether it could apply the domestic double taxation deduction to a dividend that is not included in its tax base because it relates to an overprice paid during acquisition. The DGT ruled that this is possible if the effective taxation of an equivalent amount by the previous transferors can be proven.
Cuestión planteada 1. Si el dividendo que se obtendrá por la entidad consultante registrado contablemente en la cuenta de resultados genera el derecho a la aplicación de lo dispuesto en el apartado 6 del artículo 30 del texto refundido de la Ley del Impuesto sobre Sociedades.
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