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The Spanish Supreme Court recently ruled on the criteria to be used to allocate (part of) the general management and administrative...
Welcome to the European Tax Blog.
Some of Europe's brightest legal minds look at the tax issues across Europe which could impact multinational businesses.
A recent binding tax ruling (V2200-23) issued by the Spanish tax authorities introduces a favourable change to the criteria to be met to...
The 1% income tax treatment, instead of the standard 19% tax, is available to non-Spanish tax resident alternative investment funds...
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In recent years, there has been a steep increase in criminal proceedings for tax matters in some European countries, such as France,...
In order to carry out a transaction, taxpayers are generally free to choose between different structures and tax regimes, and to choose...
There are multiple purpose test provisions pursuant to which the Portuguese tax authorities can recharacterise or disregard a transaction...
The Spanish tax authorities can challenge transactions under purposes tests in the two different general anti-abuse rules (GAARs) as well...
Across a number of European jurisdictions, relief from withholding tax may be denied where the recipient of a dividend, interest or...
The Portuguese tax authority has started to deny withholding tax refunds (requested by non-resident recipients who had not yet completed...
Since the Danish conduit cases, the Spanish tax authorities have used the beneficial ownership concept to deny the application of...
A recent decision may pave the way for non-residents with assets in Spain to benefit from significant Spanish Wealth Tax reductions. The...
The Spanish courts and tax authorities have recently issued several judgments and rulings of potential interest to high net-worth...