Valid economic rationale and concept of ‘tax advan […] Valid economic rationale and concept of ‘tax advantage’ in corporate restructurings. TEAC Rulings 6448/2022 and 6452/202 […]
Category: Tax
Corporate restructurings are a practice widely used by business groups for various reasons, among others, because all economic activity must be structured in an efficient, orderly manner and with properly managed resources in order to correctly analyse the profitability of each line of business, as well as to enhance such profitability, without any of them […]
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The deductibility of impairment losses on trade re […] The deductibility of impairment losses on trade receivables for Corporation Tax purposes and the modification of the tax […]
Loan defaults are a reality that many companies face in their day-to-day business activities. It is therefore important for taxpayers to be clear about their correct tax treatment in order to comply with their tax obligations in accordance with the regulations in force at any given time. In this publication we address the tax treatment […]
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How does the distribution of dividends affect a co […] How does the distribution of dividends affect a company when its partner is not a tax resident in Spain?
There are many cases in which a company established in Spain distributes dividends to its partner who is not a tax resident in Spain. In this type of case, both Spanish companies and non-resident partners encounter difficulties in determining the taxation of this income. This is due to the fact that not only are Spanish […]
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Personal income tax exemption for work carried out […] Personal income tax exemption for work carried out abroad
In the process of internationalisation and globalisation in which the business world is currently involved, it is increasingly common for company employees and managers to be sent temporarily from Spain to work abroad to carry out work of different levels of qualification, either for end clients or, on many occasions, for subsidiaries of the group in the […]
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Do I have to declare my shares in a company for we […] Do I have to declare my shares in a company for wealth tax purposes?
As is well known, the voluntary period for filing Personal Income Tax (hereinafter, “IRPF”) and Wealth Tax (hereinafter, “IP”) for the 2023 tax year opened on 3 April. This voluntary filing period will end on 1 July. In this blog post, we are going to focus exclusively on the IP and, specifically, on the obligation […]
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What circumstances lead to the revocation of the N […] What circumstances lead to the revocation of the NIF (TIN), consequences and how to amend the revocation
As a general rule, anyone who is going to carry out transactions with tax implications must have a NIF (TIN/Tax Identification Number), except for certain exceptions provided for in Royal Decree 1065/2007. This can be obtained either at the request of the interested party, by filing the corresponding census declaration of registration in the Census […]
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I have cryptocurrencies abroad, do I have to decla […] I have cryptocurrencies abroad, do I have to declare them?
From 11 July 2021, the obligation to provide information to the Tax Administration on the holding and transactions carried out with virtual currencies (acquisition, transmission, exchange, transfer, collections and payments), as well as the holding of those located abroad, will be established. This obligation was introduced by Law 11/2021 of 9 July on measures to […]
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REIT as a problem-solving tool in family businesse […] REIT as a problem-solving tool in family businesses: tax advantages and legal regime
One of the common grounds for disputes within the family businesses, especially when it comes to the second or third generation, is the distinction between partners who participate in the management or activity of the company, and partners who do not. It is normal that, either because of capacity or quantity, not everyone can obtain […]
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Deductibility of VAT: What is the Pro rata Rule an […] Deductibility of VAT: What is the Pro rata Rule and how does it affect businesses?
One of the most controversial aspects of the Value Added Tax (VAT) Law is the deductibility of input VAT. Companies often encounter difficulties in determining the correct way to deduct input VAT when they simultaneously carry out transactions that give rise to a right to deduct, i.e. transactions that are subject to and not exempt […]
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Tax offence. Circumstances for its assessment. App […] Tax offence. Circumstances for its assessment. Applicable penalties and how to avoid them.
What is a tax crime? The first thing to be clear about a tax offence (or, as the Criminal Code calls it, “offence against the Public Treasury”) is that it is a crime that cannot be committed by everyone, since it involves having defrauded the Treasury (whether at state, regional, provincial, or local level) of […]
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