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V1984-15 25 June 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · deducción por doble imposición interna

Application of the domestic double taxation deduction to dividends and merger income

The inquiry concerns the application of the dividend deduction and the exemption on holdings under the new Corporate Income Tax Act. The DGT clarifies that it is possible to apply the 100% deduction to dividends and merger income if the participation requirements are met, even if the income was previously exempt.

The question raised

Question raised 1. Whether a deduction under Article 30.2 of the Recast Text of the Corporate Income Tax Act shall apply to a dividend distributed to a company subject to the Recast Text of the Corporate Income Tax Act by another company to which the new Corporate Income Tax Act applies.

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