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A query was raised regarding whether dividends received by a Spanish company from other companies (S1 and S2) are exempt from Corporate Income Tax. The DGT ruled that, even if participation requirements are met, the exemption does not apply if the subsidiary entities benefit from a temporary tax exemption in their country of residence.
Cuestión planteada Si los dividendos que X y X1 reciban, con origen en las sociedades S1 y S2, estarían exentos.
Para que los dividendos estén exentos, la entidad participada no residente debe estar sujeta a un impuesto extranjero de naturaleza similar con un tipo nominal de al menos el 10%. Si la entidad participada se beneficia de una exención temporal (vacaciones fiscales), se equipara a un tipo del 0%. Por tanto, en ese periodo, no se cumple el requisito de tributación exigido por el artículo 21.1.b) de la LIS.
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