Tax law experts highlight the considerable uncertainties generated by the tax treatment of compensations granted to members of the board of directors, demanding greater legal certainty in this area. This need for certainty is shared both by managers of these entities and by professionals specialized in tax matters. The lack of clarity in tax legislation… Continue reading Fiscal Uncertainty in Socimis
Tag: Legal Certainty
Scope of the Constitutional Court’s Judgment Declaring Partial Annulment of Royal Decree-Law 3/2016
The Constitutional Court has declared the unconstitutionality of various provisions contained in the Corporate Income Tax Law, which restricted the offsetting of negative taxable bases, as well as deductions to prevent double taxation, and also required the reversal of losses from depreciated holdings previously deducted in prior fiscal years. These measures, incorporated through Royal Decree-Law… Continue reading Scope of the Constitutional Court’s Judgment Declaring Partial Annulment of Royal Decree-Law 3/2016
Tax advisor: The General Court of the European Union annuls the decision of the European Commission that declared illegal the deduction regime for indirect acquisitions in non-resident companies
The General Court of the European Union, in five judgments on September 27 th , 2023, related to cases T-826/14, T-12/15, T-158/15 and T-258/15 (consolidated), T- 252/15 and T-257/15 (consolidated), T-253/15 and T-256/15 and T-260/15 (consolidated), annuls Commission Decision (EU) 2015/314 of October 15 th , 2014, concerning state aid granted by Spain in the… Continue reading Tax advisor: The General Court of the European Union annuls the decision of the European Commission that declared illegal the deduction regime for indirect acquisitions in non-resident companies