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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...

Insights and Analysis

Carried interest schemes for asset managers

During the last decade, the shape and source of capital flows and investment have fundamentally shifted. Private capital continues to flow into all asset classes including real estate,...

News

Online intermediaries are obliged to collect Spanish VAT on sales of NFTs through their marketplaces

Due to the anonymity of non-fungible tokens’ (“NFTs”) transactions, sellers face practical difficulties in determining whether or not they should charge Spanish Value...

News

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...

Insights and Analysis

Carried interest schemes for asset managers

During the last decade, the shape and source of capital flows and investment have fundamentally shifted. Private capital continues to flow into all asset classes including real estate,...

News

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...

News

First Spanish ruling on the existence of a PE due to teleworking during and after COVID-19 lockdown

The Spanish Tax Authorities ("STA") have issued the first ruling analysing the existence of a permanent establishment ("PE") in Spain due to an employee who worked from...

Insights and Analysis

Carried interest schemes for asset managers

During the last decade, the shape and source of capital flows and investment have fundamentally shifted. Private capital continues to flow into all asset classes including real estate,...

Insights and Analysis

Spain: Law 11/2021 implementing ATAD and introducing other measures against tax 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...

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