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A company has requested a ruling on whether recovering liquidity through a capital reduction following the contribution of land parcels qualifies for the dividend exemption. The DGT has determined that if the liquidity originates from tax-paid income, the transaction is treated as a dividend distribution subject to the exemption under Article 21.1 of the Corporate Income Tax Act (LIS).
Question posed: Whether the proposed transaction would be entitled to the application of Article 21 of Law 27/2014, without the restriction established in paragraph 4 of said article being applicable.
Si se puede justificar que la liquidez distribuida corresponde a rentas fiscales generadas en la entidad e integradas en su base imponible, la operación se asimila a una distribución de dividendos. En este caso, se aplica la exención del apartado 1 del artículo 21 de la LIS y no las restricciones de los apartados 3 y 4. Esto ocurre cuando las rentas tienen consideración de ingreso en sede de los accionistas y no minoran el valor de su participación.
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