Deduction for international double taxation in the cases of application of the international tax transparency regime

Regulations: Art. 91.10 Law Personal Income Tax

In the cases in which the imputation of income is appropriate in the international tax transparency regime , the tax or levy actually paid abroad due to the distribution of the dividends will be deductible for this concept. or shares in profits, whether in accordance with an agreement to avoid double taxation or in accordance with the internal legislation of the country or territory in question, in the part that corresponds to the positive income included in the tax base.

This deduction will be made even when the taxes correspond to tax periods other than the one in which the inclusion was made.

The deduction may not exceed the full amount that in Spain would be payable for the positive income imputed to the tax base.

Note: Under no circumstances may taxes paid in countries or territories legally classified as tax havens be deducted.