According to the 2021 Annual Budget, which has entered into effect on 1 January 2021, the 100% participation exemption is reduced to 95% on qualifying dividends and capital gains to 95%. Therefore, 5% of the gross dividend and capital gain is now taxed at the standard Corporate Income Tax rate of 25%.

Please bear in mind this change does not affect the dividends paid to foreign shareholders, but only to Spanish parent companies (even within tax groups).