Double Taxation Agreements after BEPS: the impact […] Double Taxation Agreements after BEPS: the impact of the MLI, the PPT clause and the beneficial owner
Category: Tax law
Historically, Double Taxation Agreements (DTAs) have constituted a key instrument for structuring and planning international transactions. Thanks to the network of DTAs, entities and multinational groups are able to operate while minimising or eliminating instances of double taxation in cross-border transactions, such as payments of dividends, interest or royalties, among other items. That said, it […]
Read article
The application of Article 37.1.b) of the Personal […] The application of Article 37.1.b) of the Personal Income Tax Act to the transfer of shares or equity interests in unlis […]
The transfer of shares or equity interests in unlisted entities is a common transaction in closely held companies and in businesses with a strong family character. Despite its frequent occurrence, this type of transaction entails significant tax complexities arising from the application of Article 37.1.b) of Law 35/2006, of 28 November, on Personal Income Tax […]
Read article
The tax regime of ETVEs: a strategic tool in the i […] The tax regime of ETVEs: a strategic tool in the international tax planning of corporate groups
A Foreign Securities Holding Company (hereinafter, ETVE by its Spanish acronym) is a Spanish company whose principal purpose is the management and administration of shareholdings in non-resident entities. The main appeal of these entities lies in their favourable tax treatment, since, provided certain requirements are met, dividends and capital gains derived from their foreign subsidiaries […]
Read article