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Aclarado: La cuota previa a la bonificación en Patrimonio reduce la cuota del Impuesto a las Grandes Fortunas

El Impuesto de Solidaridad de las Grandes Fortunas nació con el objetivo de armonizar las asimetrías que habían surgido entre comunidades autónomas en el Impuesto sobre el Patrimonio debido a las bonificaciones aprobadas por...more

Dividend income is excluded from the EBITDA for the purpose of the Spanish interest limitation rule

The Spanish interest limitation rule establishes that net financial expenses are deductible for Spanish Corporate Income Tax ("CIT”) purposes with the annual limit of the higher of (i) 30% of the Tax EBITDA (as defined in the...more

Spain releases its long awaited draft list of non-cooperative jurisdictions

On 12 January 2023 the Spanish Ministry of Finance published a draft of its long-awaited list of non-cooperative jurisdictions. Spain has finally not followed the EU approach with some jurisdictions. The draft Spanish list...more

First Spanish ruling on the VAT treatment of the sale of NFTs

The Spanish Tax Authorities (“STA”) have issued the first ruling analysing the Value Added Tax (“VAT”) treatment of the sale of non-fungible tokens (“NFTs”) that grant the buyer a right to use an underlying digital artwork....more

Spain: Law 11/2021 implementing ATAD and other measures against fraud

The Spanish Parliament has finally approved Law 11/2021, of 9 July, on measures to prevent and fight against tax fraud (“Law 11/2021”) which implements several aspects of Council Directive (EU) 2016/1164 of 12 July 2016...more

Spanish Supreme Court opens the door to refunds of withholding taxes borne by non-EU pension funds

The Spanish Supreme Court has recently issued a judgment concluding that a Canadian pension qualifies for the same tax treatment as Spanish pension funds and is therefore entitled to obtain the refund of the withholding tax...more

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