The Spanish participation exemption on dividends and capital gains is a “full exemption” for the purposes of the Controlled Foreign Company regime

According to the Directorate General of Taxes, exempt dividends and capital gains obtained by foreign holding companies do not have to be declared in Spain. Controlled Foreign Company (CFC) regimes are traditionally anti-abuse rules aimed at avoiding the deferral of taxation of income – normally of a “passive” or non-business nature – in controlled foreign […]