Since the new Spanish Corporate Income Tax Law entered force in 2015, Spanish enterprises with a participation of at least 5% in other companies, regardless of whether these are Spanish or non-resident companies, are entitled to certain tax advantages: as well the dividends generated by these subsidiaries as the gains from a potential sale are now in their entirety exempt from taxation.
In case the Spanish company achieving these tax-free earnings is also the subsidiary of a German parent company, the dividends the latter is entitled to and the gains from a potential sale of the Spanish holding shall be exempt from non-resident income tax as well.
We shall be pleased to grant all further information required in this context.