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A company has queried whether it must make a positive adjustment to its taxable base when a received dividend reduces the accounting value of its holding, and whether it may claim the double taxation deduction. The DGT has ruled that, due to tax subrogation, these dividends must be included in the taxable base and are eligible for the deduction.
Cuestión planteada Si la entidad consultante debe realizar un ajuste positivo en su base imponible respecto de la parte del dividendo que contablemente minore el valor de adquisición de la participación y, en su caso, aplicar la deducción por doble imposición de dividendos del artículo 30.2 del texto refundido de la Ley del Impuesto sobre Sociedades.
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