Deductions from the full fee

Regulation: Article 100.11 LIS

will be deductible from the full fee:

1. The taxes or levies of an identical or analogous nature to the Corporate Tax, actually paid, in the part that corresponds to the positive income imputed in the taxable base.

   The taxes actually paid include paid by both the non resident entity and its subsidiaries, at least 5 percent.

2. The tax or levy actually paid abroad due to the distribution of dividends or profit shares, in the part that corresponds to the positive income previously included in the tax base.

   When the participation in the non-resident entity is indirect through another or other non-resident entities, they will deduct the tax or levy of an identical or analogous nature to the Corporate Tax actually paid by the latter or those in the part that corresponds to the positive income previously imputed in the tax base.

   These deductions will be applied even when the taxes correspond to different tax periods from the one in which the imputation was made.

   Taxes or levies paid in territories or countries classified as tax havens will not be deductible.

   The sum of the deductions contemplated in letters a) and b) above, may not exceed of the total amount that would have to be paid in Spain for the positive income included in the tax base.

Filling in form 200

The amount of these deductions must be entered in box [00575] "International tax transparency" on page 14 of Form 200 (see below in the section on completing Form 200 under the international tax transparency regime, point " Deductions from the full tax rate (page 14 of Form 200) ").