Spanish Corporate Tax Exemptions and Foreign Tax Credits (TRLIS)
Case of Exemption (Article 22 TRLIS)
The assumption is a Spanish company with a permanent establishment abroad that carries on business that is subject to a foreign tax similar in nature to Spanish corporate tax.
The consequence is the exemption of income from the activity obtained abroad by the Spanish company.
For example, “Ceramics La Plana”, based in Castellón, has a subsidiary called “Ceramics-Argentina” whose headquarters is in Buenos Aires. The income obtained and taxed in Argentina is exempt from Spanish corporate tax.
Case of Tax Credits (Section 32 TRLIS)
This applies when a Spanish company has interests in a foreign company that earns profits taxed abroad by a tax of a similar nature. This is taken into consideration even if
...