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Practical Manual of Companies 2022.

Special tax system of partners

Regulation: Article 10 Law 11/2009

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

This exemption will not apply to income obtained from the transfer or reimbursement of participation in the capital of companies that have opted for the SOCIMI regime , when the transferor or recipient is a taxpayer of Corporate Tax or Non-Resident Income Tax with a permanent establishment.