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A company requested clarification on whether dividend distributions affect the calculation of the Canary Islands Investment Reserve (RIC). The Directorate-General for Tax (DGT) ruled that distributions do not impact the incentive, provided that equity increases by an amount equal to the RIC provisioned.
Question raised 1. Whether, in the present case, the distribution of the dividend has any impact on the calculation of the RIC.
The distribution of dividends does not affect the RIC incentive provided that equity increases by the amount of the allocated reserve. To calculate said increase, profits that are not considered undistributed shall not be taken into account. Likewise, the unavailable reserves of the RIC shall not be taken into account as equity for the purpose of determining the increase in equity for the Corporate Tax capitalization reserve incentive.
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