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The taxpayer inquired whether separating homogeneous securities into sub-accounts (A and B) allows for the application of the Article 21 LIS exemption to sub-account A without sub-account B affecting its eligibility. The DGT ruled that the exemption is applicable provided the securities meet the legal requirements, regardless of whether they are held in separate sub-accounts.
Question posed: Whether the operation of separating certain homogeneous securities into sub-accounts A and B, differentiated within the trading portfolio, enables the application of Article 21 of the Corporate Income Tax Law to the dividends and income derived from the transfer of the securities recorded in sub-account A, provided that the holding period and participation requirements are met therein, such that sub-account B does not contaminate sub-account A in any way.
The exemption to avoid double taxation on dividends and income derived from the transfer of securities may be claimed provided that the securities meet the requirements of paragraphs a) and, where applicable, b) of Article 21.1 of the LIS. This is applicable regardless of whether the securities are divided into sub-accounts. The entity must provide documentary evidence of compliance with the requirements to justify its right to the exemption.
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