The Spanish National Court (Audiencia Nacional) gave its decision on 14 November 2013 in the case of Sabic Innovative (previously GE Plastics de España) against the tax administration (Appeal 367/2010). Details of the decision are summarized below.
(a) Facts. In 2001, the Dutch holding parent company GE International Benelux BV, (hereinafter GEIB) transferred to its Spanish subsidiary GE Plastics de Espana (hereinafter GEPESA) 100% of the shares of its Dutch operative subsidiary GE Europe Energy…
OrbitaxSpanish National Court rules intra-group debt transaction constitutes fraud of law
