A decision of the Spanish National Court was published on 24 May 2023 on whether an Icelandic frozen fish company, Icelandic Group EHF (Icelandic), qualified for a tax exemption on capital gains from the sale of its wholly-owned Spanish subsidiary. The subsidiary was sold to an unrelated Icelandic company, Solo Seafood EHF, in 2016. In January 2017, Icelandic declared the capital gain and self-assessed the Non-Resident Income Tax due, which amounted to approximately EUR 2.5 million. However,…