Spanish Supreme Court Confirms Brazilian Interest on Equity Capital Eligible for Participation Exemption

A recently published decision of the Spanish Supreme Court confirms a 27 February 2014 decision of the lower National Court that Brazilian interest on equity capital (juros sobre o capital proprio - JCP) qualifies as dividends for the purpose of Spain's participation exemption. JCP is an alternate distribution by Brazilian companies to shareholders in proportion to their participation in the company, and unlike dividends, is deductible for the distributing company subject to certain condition…