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A company inquired whether the 'interest on equity' (JSCP) of a Brazilian subsidiary should be classified as dividends or interest. The DGT determines that, pursuant to the Convention with Brazil, they are interest, but for Corporate Income Tax purposes in Spain, they are dividends.
Question posed: Whether the collection of JSCP should be classified as a dividend or as interest.
For the application of the Spanish-Brazilian Convention, the JSCP are considered interest because Brazilian tax legislation treats them as returns on amounts provided as loans. However, under Spanish domestic regulations, they have the legal nature of dividends. Therefore, the exemption under Article 21 of the LIS does not apply when generating a deductible expense in the payer entity, but a 20% deduction for the elimination of double taxation applies according to the Convention.
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