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V2512-20 23 July 2020 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · dividendo flexible

DGTC does not respond to query due to lack of necessary factual prerequisites

A company asks about the retention procedure in a scrip dividend flexible dividend scheme and the obligations of depositary entities and shareholders. The DGTC decides not to respond to the questions raised.

The question raised

Question raised In relation to the operation of the flexible dividend of the consulting entity, the following is raised:

The DGT's ruling

The Directorate General of Taxes does not proceed to answer the questions raised regarding the withholding procedure, the obligations of the parties involved, or the withholding applied to entities such as SICAVs or pension funds, as it considers that the necessary factual circumstances to resolve the matter are not met.

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