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Practical Income Manual 2021.

Imputation of incomes in the international tax transparency scheme

Regulations: Art. 91 Law Personal Income Tax

The international tax transparency regime involves the attribution to a person or entity resident in Spanish territory of certain income obtained by a majority-owned entity that resides abroad when the tax on those income abroad is significantly lower than that which would have occurred. in Spanish territory, an imputation that occurs even if the income has not been effectively distributed.

  1. Scope
  2. Content of the special regime and moment of imputation
  3. Measures to avoid double taxation
  4. Special case: entities resident in countries or territories classified as non-cooperative jurisdiction
  5. Specific formal obligations derived from the international tax transparency regime