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A Spanish company has requested clarification on how to calculate the double taxation relief for interest income received from Brazil that is exempt from withholding tax in that country. The Directorate General for Taxes (DGT) has ruled that, pursuant to the relevant Double Taxation Convention, such interest must be deemed to have been taxed in Brazil at a rate of 20% for the purposes of calculating the relief.
Question raised For the purposes of applying the deduction under Article 31 of the LIS, what would be the base and the deduction percentage and, if applicable, the limit thereof?
Para la deducción del artículo 31 de la LIS, se considera que los intereses obtenidos en Brasil han tributado al 20%, independientemente de su tributación efectiva. La base de la deducción será el diferencial de intereses (intereses percibidos menos intereses satisfechos). El importe de la deducción será la menor de: el impuesto considerado pagado en Brasil (20%) o la cuota íntegra que en España correspondería por esas rentas.
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