Dividend taxation: domestic companies may reduce received subsidiary dividends when the subsidiary's dividend tax is paid. Amendment permits a domestic company to reduce its dividend distribution tax base by dividends received from a subsidiary if the subsidiary has paid tax on those dividends or, in the case of a foreign subsidiary, if tax on those dividends is payable by the domestic company under the specific foreign-dividend tax provision, and provides that the same dividend amount may not be taken into account for reduction more than once.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividend taxation: domestic companies may reduce received subsidiary dividends when the subsidiary's dividend tax is paid.
Amendment permits a domestic company to reduce its dividend distribution tax base by dividends received from a subsidiary if the subsidiary has paid tax on those dividends or, in the case of a foreign subsidiary, if tax on those dividends is payable by the domestic company under the specific foreign-dividend tax provision, and provides that the same dividend amount may not be taken into account for reduction more than once.
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