8.1.3.2.3. Imputation of positive income

AMOUNT OF POSITIVE INCOME ATTRIBUTABLE

The amount of positive income to be imputed will be calculated in accordance with the principles and criteria established in the Corporate Tax regulations for determining the taxable base.

For these purposes, the exchange rate in effect at the close of the financial year of the entity not resident in Spanish territory will be used.

The same positive income may only be imputed once, regardless of the form and entity in which it is manifested.