A bill has recently been proposed that would strengthen Spain's existing controlled foreign company (CFC) rules. If passed, the amendments would apply from 1 January 2015.
Under the proposed bill, the holding and taxation conditions for a CFC are generally the same as the current rules: 50% or more participation in the capital stock, equity, results or voting rights of a non-resident subsidiary, and taxation of income at a rate of 75% or lower than the tax that would have been imposed in Spa…