Taxation of Collective Investment Institutions

Article 53 regulates the taxation of partners or participants of Collective Investment Institutions, establishing in section 2 that the taxation of partners or participants of IIC incorporated or domiciled in a Member State of the EU and registered in a special registry of the CNMV will occur when the shares are transferred or dividends are distributed.

It follows from this provision that the income attribution regime will not apply to these incomes.

As of January 1, 2021, the non-applicability of article 53.2 of the LIS to UCITS established in the United Kingdom and registered with the CNMV for marketing implies that a case-by-case analysis must be carried out to determine the taxation of these incomes.