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Practical Handbook for Companies 2021

Special tax system of partners

Regulation: Article 10 Law 11/2009

Regarding the treatment of dividends distributed out of profits or reserves for which the special tax regime established in Law 11/2009 has been applied, when the recipient is a taxpayer of Corporate Income Tax or Non-Resident Income Tax with a permanent establishment, the exemption established in article 21 of the LIS will not apply.

This exemption will also not apply to income obtained on the transfer or redemption of a stake in the capital of companies that have opted for the SOCIMI regime, when the transferor or recipient is a taxpayer of corporate income tax or non-resident income tax with a permanent establishment.