/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/2025-08-22-08-27-21-361-68a829e96003c823f24ebb63.jpg)
In a landmark decision, Spain’s National Court (Audiencia Nacional) has applied CJEU case law on the free movement of capital to conclude...
/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/2025-08-22-14-26-06-023-68a87dfe191ca197084e4770.jpg)
Re-domiciliations and cross-border mergers can be great options for a restructuring and, within the EU, the rules governing both types of...
On 19 December 2024, the Court of Justice of the European Union (CJEU) delivered a significant decision in the case of Credit Suisse...
The Spanish Supreme Court recently ruled on the criteria to be used to allocate (part of) the general management and administrative...
/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/617c127b49b23409885c6f85/2022-03-24-15-55-42-694-623c947ef636e915fc6a617b.jpg)
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...
/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/5bade02498fcca12902fe597/2019-09-17-10-45-27-851-5d80b9478cb62309f8e0c406.jpg)
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...
In a recent ruling issued on 8 June 2023, the Spanish Supreme Court followed the Court of Justice of the European Union’s decisions in...
As mentioned in a previous post, the three historical territories of the Basque Country in Spain (as well as Navarre) have their own tax...