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Practical Manual for Companies 2024.

Intercompany internal double taxation deduction

According to the provisions of article 32 of Law 20/1990, of December 19, on the Tax Regime of Cooperatives, the partners of protected cooperatives have the right, in relation to the cooperative returns , to a deduction in the fee of 10 percent of those received.

In the event that the returns come from a specially protected cooperative and that, therefore, they would have benefited from the bonus provided for in article 34 of Law 20/1990, this deduction will be 5 percent of said returns.

Filling in form 200

In the box [00577] "Deduction for internal inter-company double taxation at 5/10% (cooperatives)" on page 14 of form 200, the deduction resulting from applying the percentage of 10% (5% in the case of specially protected cooperative companies) on the amount of returns computed by the taxpayer in the year will be recorded, provided that said returns come from cooperative companies that have themselves paid tax without any bonus or reduction for Corporate Income Tax.

Keep in mind:

The deduction is determined, for each homogeneous group of securities, as follows:

  • Deduction for inter-company double taxation at 5 percent = A x 0.05
  • Deduction for inter-company double taxation at 10 percent = A x 0.10

Where "A" is the total amount of the returns with the right to deduction