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Practical Manual of Companies 2022.

Deductions from the full fee

Regulation: Article 100.10 LIS

The following will be deductible from the full fee:

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

    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 income positive tax previously included in the tax base.

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

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

    Taxes or levies paid in countries or territories classified as non-cooperative jurisdictions will not be deductible ##.

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

Filling in form 200

The amount of these deductions must be entered in box [00575] “International tax transparency (art. 100.10 LIS)” on page 14 of form 200 (see below in the completion section of model 200 in the international tax transparency regime, point Deductions in the full quota ).