Other significant exemptions and exclusions under the Spanish CFC rules include:
•	De minimis rule: CFC income is not attributed if the passive income subject to the regime is lower than 15% of the foreign entity’s total income.

•	Participation exemption carve out: Dividends and capital gains derived from significant participations in active subsidiaries are generally excluded, aligning with Article 21 of the Spanish CIT Law.

•	Tax treaty and information exchange jurisdictions: When the CFC is resident in a jurisdiction with a tax treaty containing an effective exchange of information clause, only certain passive income is attributed.

•	Permanent establishment exclusion: Profits of a foreign permanent establishment that are already included in the Spanish tax base are not subject to the CFC rules.