How the DGT's position has evolved
Current position
Dividends from resident entities may be exempt if a holding of at least 5% is maintained uninterruptedly during the year prior to the date on which the profit becomes due. In this case, it is not necessary to analyze foreign tax. The exempt amount must be reduced by 5% for management expenses.
The DGT's position remains constant regarding the application of the 5% reduction for management expenses under the exemption regime for dividends and income from the transfer of holdings. The rulings confirm that this amount is applied whenever the requirements of Article 21.1 of the LIS (Corporate Income Tax Law) are met.
Analysis based on 22 of 24 rulings with a stated position. Updated 24 September 2026.