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A Spanish company has requested clarification on the taxation of dividends from a French subsidiary distributed less than a year after its acquisition. The Directorate General for Taxes (DGT) has ruled that if the dividends originate from reserves generated prior to the acquisition, they do not constitute taxable income.
Cuestión planteada ¿Cuál es el régimen de tributación aplicable a los dividendos que perciba la empresa matriz española de su filial francesa si los percibe en plazo inferior a un año desde la fecha de la adquisición de la totalidad de las participaciones?
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