Spain Tax News

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Spanish National Court

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Treaty between Spain and Mexico – Spanish Tax Administration clarifies scope of withholding tax applicable to transfer of immovable property located in Spain

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Treaty between Spain and Jamaica – details

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President announces new tax measures to Parliament

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Treaty between Spain and Trinidad and Tobago – details

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European Commission refers Germany to ECJ over taxation of outbound dividends

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Treaty between Spain and Trinidad and Tobago signed

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Exchange of information agreement between Netherlands in respect of Netherlands Antilles and Spain – details

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Treaty between Spain and Ireland – Spanish Tax Administration applies dynamic interpretation for "royalties"

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Treaty between Colombia and Spain enters into force

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ECJ: Advocate General finds Belgian withholding tax on interest paid to companies resident in other Member States compatible with EC freedom of establishment – details

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Preliminary ruling requested from ECJ regarding Belgian anti-abuse provision concerning exceptional and gratuitous advantages

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Preliminary ruling requested from ECJ on interpretation of EC Parent-Subsidiary Directive with respect to Italian tax on dividend adjustment (General Beverage)

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ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies resident in other Member States justifiable restriction on EC freedom of establishment – details

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Treaty between Spain and Kuwait – signed and details

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ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies in other Member States justifiable restriction on EC freedom of establishment

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OECD released 2008 Model Tax Convention

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Discussion draft on New Art. 7 of OECD Model – details

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Treaty between Spain and Saudi Arabia enters into force

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Preliminary ruling requested from ECJ on interpretation of Merger Directive in connection with scheme to avoid Netherlands property transfer tax

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OECD Council approves 2008 Model Tax Convention

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Treaty between Denmark and Spain terminated

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Comments on draft contents of 2008 update to Model Tax Convention published

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European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends

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ECJ: Decision by reasoned order in UK CFC and foreign dividend test case

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ECJ: Advocate General finds Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive – details

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European Commission closes infringement procedure against Luxembourg concerning taxation of dividends

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ECJ: Non-deductibility of foreign PE losses in Germany compatible with EC freedom of establishment

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ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital

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Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)

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