Participation exemption on dividends

Following the participation exemption rule, the corporate profit tax is not imposed on dividends received from an entity in which the entity receiving the dividends has been holding an amount of shares entitling it to more than 10% of the total amount of votes for at least 12 subsequent months including the moment of dividend distribution.

However, this rule is not applicable if foreign entity paying the dividends is registered or otherwise organised in offshore territories or payment of dividends is subject to General anti-avoidance rule.