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Practical Income Manual 2021.

Other measures to avoid overtaxation of imputed income

Regulations: Art. 92.6 of Law Personal Income Tax

The imputation regime discussed in this section is complemented by the measures established to avoid overtaxation of imputed income.

To this end, dividends or shares in profits, including interim dividends, distributed by the first transferee in the part that corresponds to the amount that has been imputed by the taxpayer, will not be charged to the personal tax of the partners of the first transferee. of image rights as a consequence of the imputation regime.

In the case of distribution of reserves, the designation contained in the social agreement will be followed, with the latest amounts paid to said reserves being understood to be applied.

Dividends or shares distributed by the first transferee that, in application of the above, have not been integrated into the tax base of the partners, will not entitle them to the deduction for international double taxation.

Note: The same amount may only be charged once, regardless of the form and the person or entity in which it appears.