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Practical Manual of Companies 2021.

Specialities in the settlement of Corporation Tax (pages 13 and 14 of form 200)

1. Adjustments arising from the application of the special system (page 13 of form 200)

In relation to the imputation of positive income obtained by one or several non-resident entities in Spanish territory or by a permanent establishment, provided that the factual assumptions contemplated in article 100 of the LIS, occur. ##1##The following adjustments must be made in boxes [00387] and [00388] “International tax transparency” on page 13 of form 200:

  • In box box [00387] taxpayers must enter the amount of positive income obtained by one or several non-resident entities in Spanish territory or by a permanent establishment that they allocate to their tax base, according to the rules established in article 100 of the LIS.

  • In box [00388] taxpayers must include the amount of dividends or shares in profits, in the part that corresponds to the positive income that has been included in the tax base.

    They must also include in this box the amount of distributed dividends that correspond to income included in the tax base in a previous tax period.

2. Deductions in the full fee (page 14 of model 200)

Entities that apply the special regime of international tax transparency and have imputed in their tax base the positive income of one or several non-resident entities in Spanish territory or of a permanent establishment, may deduct from your full fee, the following amounts established in article 100.10 of the LIS (see section « Deductions from the full fee »).

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

    The taxes actually paid include those paid by both the non-resident entity and its investees of at least 5 percent.

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

The amount of these deductions will be collected in box box [00575] “International tax transparency (art. 100.10 LIS)” on page 14 of form 200.

Keep in mind:

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

    Under no circumstances will taxes paid in countries or territories classified as non-cooperative jurisdictions be deducted.

    The sum of the deductions included in letters a) and b) of article 100.10 of the LIS, may not exceed of the full quota that in Spain It would be necessary to pay for the positive income included in the tax base.

  • For tax periods beginning on or after January 1, 2016, section 2 of the fifteenth Additional Provision of the LIS establishes that Taxpayers whose net amount of turnover is at least 20 million euros during the 12 months prior to the date on which the tax period begins, must take into account that the amount of the deductions to avoid international double taxation provided for in articles 31, 32 and 100.10 of the LIS, as well as those deductions to avoid double taxation referred to in the twenty-third transitional provision of this Law, may not jointly exceed of 50 percent of the taxpayer's full fee.

Completion of the table “Net amount of turnover for the twelve months prior to the start date of the tax period” (page 21 of form 200)

For tax periods beginning on or after January 1, 2019, information on the net amount of the turnover must be included on page 21 of form 200, of the twelve months prior to the start date of the tax period, for the purposes of determining the application of the limit established in the fifteenth Additional Provision of the LIS.

For these purposes, when completing the box [00575] a breakdown window will open (except in cases where the table has already been completed previously). on page 21 of form 200), in which the taxpayer must indicate whether the net amount of the turnover during the twelve months prior to the start date of the tax period has been less than 20 million, at least 20 million of euros, but less than 60 million or at least 60 million euros. The option marked by the taxpayer will be transferred to the table "Net amount of turnover for the twelve months prior to the start date of the tax period" on page 21 of form 200.

The option marked by the taxpayer will also be taken into account to determine the limits in the calculation of the accounting corrections derived from the application of article 11.12 of the LIS, the compensation of negative tax bases and the compensation of contributions for losses of cooperatives, so once the table on page 21 of model 200 is completed, it is not possible to will be shown again on other screens.

3. Informative specialties (page 25 of model 200)

  1. On page 25 of form 200, entities that apply the special international tax transparency regime must detail the following data for each non-resident entity for which it has included positive income in its tax base:

    • Name or Social reason.

    • Registered office.

    • Country/territory key. The two-letter code from the list of country or territory codes contained in Annex II of Order EHA /3496/2011, of December 15, will be entered as the country/territory code ( is collected at the end of Chapter 3 of this Practical Manual).

    • Amount of positive income that must be included in the tax base.

    • List of administrators of the non-resident entity and place of its tax domicile.

    In box [00387] "International tax transparency (art. 100 LIS)" the total amount of the income that has been included in the tax base by application of the tax transparency regime will be entered. international.

    [00387] = A + B + C + D + E + F

    The amount entered here will be transferred to the equally numbered box on page 13 of form 200.

  2. Additionally, the entities to which this special regime applies, must present, together with the declaration for this Tax, the data relating to the non-resident entity in Spanish territory to which reference in article 100.12 of the LIS (see section « Information obligation » of the special international transparency regime).

    In relation to the presentation of this documentation, see the section « Documentation that must be submitted together with the declaration » of Chapter 1 of this Practical Manual.