ETVEs are efficient corporate vehicles for investments abroad. These entities benefit from a special tax regime that significantly reduces the tax burden on foreign profits, which makes these vehicles highly attractive to international investors. However, the application of the special tax regime requires the fulfilment of several requirements. In the following, we will discuss the… Continue reading Tax advisor: Foreign Securities Holding Entities (ETVE): Considerations about the application of the ETVE regime
Tag: tributación
Tax advisor: EU Directive proposals and their impact on multinational companies’ taxation
The European Union has presented two directive proposals that could have a significant impact on the taxation of multinational corporations in Europe. Both proposals fall under the umbrella of BEFIT but differ in their objectives and scope.One of them pertains to the regulation of transfer pricing and aims to incorporate the principle of fair competition… Continue reading Tax advisor: EU Directive proposals and their impact on multinational companies’ taxation
Tax advisor:Analysis of the justification for applying the median in transfer pricing adjustment
In the opinion of the National High Court, the justification provided by the tax authority regarding the excessive breadth of the profit margins is not considered detailed enough to support the application of the median as explained. Therefore, this objection is accepted, and it is determined that the application of the lower point within the… Continue reading Tax advisor:Analysis of the justification for applying the median in transfer pricing adjustment
Tax advisor: The Central Economic-Administrative Court (TEAC) establishes criteria affecting family business succession
Spanish Tax Authority,requires donors to apply capital gains tax in the IRPF on assets transferred in the operation that are not related to business activity. According to a resolution by The Central Economic Administrative Tribunal (TEAC) has upheld an approach that discourages the transfer of family businesses during the owner’s lifetime. According to a TEAC… Continue reading Tax advisor: The Central Economic-Administrative Court (TEAC) establishes criteria affecting family business succession
Tax advisor: Key changes in Spanish tax legislation in compliance with the EU Directive 2021/514
Law 13/2023, which amends the General Tax Law and other tax regulations in compliance with EU Directive 2021/514, establishes in its Final Provision 5th a new wording of the limitation rule for the deductibility of financial expenses in Article 16 of the Corporate Income Tax Law (LIS). This modification is carried out to align Spanish… Continue reading Tax advisor: Key changes in Spanish tax legislation in compliance with the EU Directive 2021/514
Tax advisor: Franchised VAT, is it all it seems?
2024 is shaping up to be the year when taxpayers under the simplified VAT regime and in objective estimation for income tax (IRPF) should start planning their transition and adapting to the recent tax regimes. For the past few months, the government and social agents have been discussing the implementation of European Directive 2020/285, which… Continue reading Tax advisor: Franchised VAT, is it all it seems?
Tax advisor: The DGT rules on the taxation of the dissolution of a co-ownership of a property encumbered with a mortgage
The Directorate General of Taxes studies in the binding consultation V0027-23 of January 11 the taxation of an operation of dissolution of community of goods in which a property is awarded to one of the co-owners and a compensation is made to the remaining owner. The DGT states that it does not matter if the… Continue reading Tax advisor: The DGT rules on the taxation of the dissolution of a co-ownership of a property encumbered with a mortgage
