126.96.36.199.3. Imputation of positive income
AMOUNT OF POSITIVE TAXABLE INCOME
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 tax base.
For these purposes, the exchange rate in effect at the end of the financial year of the non-resident entity in Spanish territory will be used.
The same positive income may only be subject to imputation once, regardless of the form and entity in which it manifests itself.