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July 30, 2026

This guide details the rules on Exempt Income, explaining the automatic exemption for dividends from Resident Persons under Article 22. It extensively covers the Participation Exemption under Article 23, which exempts foreign dividends and capital gains from a 'Participating Interest.' The guide synthesizes the conditions for an ownership interest to qualify, clarifying the 5% ownership test, the 12-month holding period, and the 'subject to tax' requirement for the Participation. It also establishes the relationship with deductible expenditure, noting the non-deductibility of related expenses as per Article 28, providing a comprehensive view.

Exempt Income: Dividends and Participation Exemption

Corporate Tax Guide | CTGEXI1

October 2023

1. Glossary

2. Introduction

2.1. Overview
2.2. Purpose of this guide
2.3. Who should read this guide?
2.4. How to use this guide
2.5. Legislative references
2.6. Status of this guide

3. Dividends and other profit distributions

Figure 2: Overview of conditions to qualify as a Participating Interest

Contents