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A Luxembourg company asks how to tax the distribution of an issuance premium from a Spanish S.L. The DGT clarifies that, where shares are not traded, the amount may be considered capital gains under certain capital limits.
Question posed - Interpretation of Article 25.1.e) of the Personal Income Tax Law (LIRPF).
In the distribution of share premiums of securities not admitted to trading on regulated markets, the amount obtained is considered income from movable capital, subject to the limit of the positive difference between the value of equity (at the close of the last fiscal year prior to the distribution) and the acquisition value. To calculate equity, previously distributed profits and legally unavailable reserves generated after acquisition must be deducted. If classified as income from movable capital, it shall be taxed in Spain under the Non-Resident Income Tax (IRNR) subject to the limits of the applicable Convention.
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