Our Flashes
Income Tax Law: Transfer Pricing Accreditation
The National Audicence, in the statement dated May 31st 2023, has deemed that, in the transfer pricing adjustment carried out, the reference to the fact that the margins are...
Modification of the calculation for limiting financial expenses
In relation to the calculation of the limitation of financial expenses for the purpose of determining the taxable base of the Corporation Tax, it should be noted that in the BOE...
ETL GLOBAL Tax Working Group
ETL GLOBAL Tax Working Group, in which Audiconsultores ETL GLOBAL participates, had published a summary of the main tax incentives considered in the European Union countries and...
Income Tax Law – Considerations by the inspection for Related Operations
The Supreme Court, in the statement dated June 21st, 2023, has confirmed the TEAC criteria and considers that, when the services provided by the partner to the related party, and...
Form 232. Operations among related parties
As every year, from the 1st to the 30th of November, taxpayers of the Corporate Tax Law (CTL) and the Non-Resident Income Tax (NRIT) who operate through a permanent establishment...
IRNR – The burden of proof of abuse in the exemption from the Non-Resident Income Tax corresponds to the Tax Authorities
The Supreme Court, in its Judgment of April 19, 2023, has established as a doctrine that the burden of proof of the abuse that prevents taking advantage of the exemption in the...
Wealth Tax – Challenging the tax returns for the years 2021 and 2022
In April 2021 the Constitutional Court admitted an appeal that questioned the constitutionality of the Wealth Tax following the reforms introduced by the General State Budget...
IS – Unconstitutionality of legislation 3/2016
The Spanish National Audience, a Spanish high Court, has recently raised an exception of unconstitutionality before the Constitutional Court (CC), relating to Royal...
Corporate Income Tax – Permanent Establishment in Spain
The General Directorate of Taxes, in its binding consultation V2612-22, of 12/23/2022, has applied the doctrine of "complex operational settlement", which began from several...
Spanish Wealth Tax – Taxation of a German resident who owns a property in Ibiza through a Company
The General Directorate of Taxes (DGT) has issued on February 1, 2023 the binding consultation V0107-23 on the taxation in the Wealth Tax (WT) of a German tax resident who owns...
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