2/26/2021 12:00:00 AM The Spanish tax court places the blame on the Spanish tax authorities' abusive use of the anti-abuse rules By María González Cuervo In broad terms, general anti-abuse rules tend to lead to uncertainty insofar as they are built on vague legal concepts such as the...
2/19/2021 3:25:50 PM Peruvian Tax Court decision on beneficial ownership post-BEPS By Walker Villanueva The Peruvian Tax Court (Tribunal Fiscal) denied the application of the favourable withholding tax rate provided for in Article 12...
2/18/2021 9:51:58 AM HMRC’s commitments to building and maintaining public trust in tax administration By Zoe Andrews HMRC has powers to ensure everyone “pays their fair share of taxes” and in some cases, particularly where the powers tackle fraud,...
2/17/2021 1:36:19 PM Why are non-Spanish tax residents taxed in Spain on gifts and inheritances of non-Spanish securities and bank deposits? By Miguel Pérez Santiago Tórtola Nowadays, due to factors such as the greater mobility of people and capital, inheritances and gifts with an international component have...
2/5/2021 10:01:01 AM Finnish Group Relief for Cross-Border Tax Losses - The legacy of Marks & Spencer finally prevails By Einari Karhu A significant milestone was reached in EU tax law in the context of cross-border group taxation when the Court of Justice of the European...
2/2/2021 12:00:00 AM Non-Spanish resident pension funds are entitled to the refund of withholding tax on dividends paid by Spanish resident companies By Guillermo Canalejo Blanca García A 22 December 2020 ruling from the Spanish Supreme Court (the Ruling) has confirmed that taxing non-Spanish resident pension funds on...