22.214.171.124.2. Other issues
In addition, the following issues must be taken into account, among others:
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
Dividends or shares in profits distributed by the first transferee will not be included in the tax base of the partners of the first transferee in the part that corresponds to the amount that has been attributed to the natural person who owns the image.
In the case of distribution of reserves, the designation contained in the social agreement will be followed, with the latest amounts paid to said reserves being understood to be applied.
Said dividends or participations will not give the right to deduction for international double taxation.
INTERNATIONAL CONVENTIONS AND FORAL REGIMES
The income allocation regime for the transfer of image rights will be understood without prejudice to the provisions of the international treaties and agreements that have become part of the internal regulations and the regional tax regimes of Concert and Economic Agreement in force. respectively, in the Historical Territories of the Basque Country and in the Foral Community of Navarra.