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The taxpayer asks whether the deduction provided in Article 30.2 of the Recast Text of the Corporate Income Tax Law (TRLIS) can be applied to dividends from companies subject to the new Corporate Income Tax Law and what occurs in the event of a merger. The DGT responds that the 100% deduction is applicable if the participation requirements are met and that said deduction also extends to income accounted for through a merger.
Question raised 1. Whether the deduction provided in Article 30.2 of the Recast Text of the Corporate Income Tax Law shall apply to a dividend distributed by a company subject to the Recast Text of the Corporate Income Tax Law to another company to which the new Corporate Income Tax Law is applicable.
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