Residence in tax haven

Regulation: Article 100.14 LIS

When the participating entity resides in a country or territory qualified as a tax haven it will be presumed that:

1. The circumstance provided for in letter b) of article 100.1 of the LIS is met.

2. The income of the participating entity meets the characteristics of article 100.3 of the LIS.

3. The income obtained by the participating entity is 15% of the acquisition value of the participation.

The presumptions contained in the preceding letters will admit proof to the contrary.