b) Special rules

• The attributable income will be determined in accordance with the provisions of the regulations governing Corporate Income Tax, in the cases where all The members of the entity under the income attribution regime are taxpayers of Corporate Income Tax and are not considered asset-holding companies or Non-Resident Income Tax with a permanent establishment.

• The determination of the income attributable to taxpayers of the Non-Resident Income Tax without a permanent establishment will be carried out in accordance with the provisions of Chapter IV of the consolidated text of the Non-Resident Income Tax Law, approved by Royal Legislative Decree 5/2004, of March 5 ( BOE of 12).

• Taxpayers subject to Corporation Tax and Non-Resident Income Tax with a permanent establishmentThose who are members of an entity under an income attribution regime that acquires shares or holdings in collective investment institutions will include in their taxable base the amount of income recorded or that must be recorded from the aforementioned shares or holdings. Likewise, they will include in their taxable base the amount of income from movable capital derived from the transfer to third parties of own capital that has accrued in favor of the entity under the income attribution regime.

Special case: negative income from foreign sources

When an entity under the income attribution regime obtains foreign source income from a country with which Spain does not have a double taxation agreement with an information exchange clause, negative income exceeding positive income obtained in the same country and from the same source will not be taken into account. The excess will be accounted for in the following four years as positive income is obtained from the same country and source.