Other measures to avoid overtaxation of imputed income

Regulations: Art. 92.6 of Law IRPF

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

For this purpose, the dividends or profit shares, including interim dividends, distributed by the latter in the part corresponding to the amount that has been imputed by the taxpayer holding the image rights as a result of the imputation regime, will not be imputed in the personal tax of the partners of the first transferee.

In the event of distribution of reserves, the designation contained in the corporate agreement will be observed, with the last amounts paid being understood to be applied to said reserves.

Dividends or shares distributed by the first transferee that, in accordance with the above, have not been included in 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 to whom it is expressed.