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A taxpayer inquires whether dividends from a Hong Kong company must be computed to calculate the limits of the international tax transparency (TFI) regime. The DGT clarifies that if the dividends meet the exclusion requirements, they are not included in the calculation of the 15% income or 4% revenue thresholds.
Question raised 1) Regarding the dividends to be received by the Hong Kong company A, originating from the Hong Kong company Z, if more than 85% of the income obtained by company A consists of the dividends received from Z and less than 15% of the income of A comes from other financial income, must the natural person shareholder of A apply the international tax transparency regime regulated in Article 91 of the Personal Income Tax Law.
To apply the limits of Article 91.3 of the LIRPF, only income not included in the exclusions of paragraph 2 must be computed. If the dividends originate from entities in which more than 5% is held, which comply with material/personal management requirements and obtain at least 85% of their income from business activities, these dividends are not computed to reach the 15% income or 4% revenue limits. Income from the provision of services is not subject to said limits.
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