8.1.4.1.2. Other issues

In addition, the following issues, among others, must be taken into account:

INTEGRATION INTO THE TAX BASE

The imputation will be made in the general tax base, in accordance with the provisions of article 45 of the Tax Law.

DISTRIBUTION OF DIVIDENDS

The dividends or profit shares distributed by the latter in the part corresponding to the amount attributed to the natural person who owns the image will not be included in the tax base of the partners of the first transferee.

In the event of distribution of reserves, the designation contained in the corporate agreement will be observed, with the last amounts paid being understood to be applied to said reserves.

Such dividends or shares will not give rise to any deduction for international double taxation.

INTERNATIONAL AGREEMENTS AND FORAL REGIMES

The income imputation regime for the transfer of image rights shall be understood without prejudice to the provisions of the international treaties and agreements that have become part of the internal legal system and the regional tax regimes of Economic Agreement and Convention in force, respectively, in the Historical Territories of the Basque Country and in the Foral Community of Navarre.