The Contentious-Administrative Chamber of the Supreme Court has established that the Tax Administration has the burden of proving the abuse that prevents the application of the exemption in the Non-Resident Income Tax (IRNR). The Supreme Court has analyzed the case law of the Court of Justice of the European Union, and adjusts its doctrine to… Continue reading Tax Advisor: The Supreme Court establishes that the Tax Administration Agency has the burden of proving the abuse of the IRNR exemption