The High Court of Justice of Catalonia has confirmed that dividends received by a Spanish tax-resident individual from a Brazilian company are entitled to a full tax exemption as set out by the Brazil-Spain double taxation treaty. The decision deals with individual taxpayers, but professional services company EY notes that it could be interpreted as applying to dividends derived by a Spanish tax-resident company from its Brazilian subsidiaries.
News Source：【EY 2022/08/15】