Other issues

In addition, the following issues, among others, must be taken into account:

Integration into the taxable base

Positive income from each of the aforementioned sources will be allocated to the general tax base, in accordance with the provisions of article 45 of the Tax Law.

Formal obligations

Taxpayers to whom this imputation regime applies must submit the following data relating to the non-resident entity together with their personal income tax return:

• Name or company name and location of registered office.

• List of directors and their tax domicile

• Balance sheet and profit and loss account and the report

• Amount of positive income that must be included in the tax base.

• Justification of the taxes paid with respect to the positive income that must be included in the tax base.

International agreements and foral regimes

The international tax transparency regime shall be understood without prejudice to the provisions of the international treaties and agreements that have become part of the internal legal system and the regional tax regimes of Economic Agreement and Convention in force, respectively, in the Historical Territories of the Basque Country and in the Foral Community of Navarre.