Spain Tax News
AG: Most-favoured nation treatment and Community preference do not require extension of the tax sparing credit under tax treaties with Brazil and Greece to third countries
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
Accession Convention to Arbitration Convention for 10 new Member States ratified by Spain
Treaty between Malaysia and Spain – details
ECJ: Finnish group contribution regime compatible with EC Law – details
ECJ: Interprets anti-avoidance clause under the Merger Directive with respect to Danish rules on taxation of exchanges of shares – details
EU Commission refers Greece to ECJ concerning discriminatory taxation of dividends
Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published
EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
Treaty between Spain and Saudi Arabia signed
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details
ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details
Treaty between Spain and Costa Rica ratified
ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
International tax conference on CCCTB held in Berlin
Revised Commentary on Article 7 of OECD Model released
Protocol to treaty between Switzerland and Spain enters into force - details
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
Treaty between Spain and United Arab Emirates enters into force – details
Treaty between Venezuela and Spain – application of MFN clause to interest income
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
Final Report on Improving the Resolution of Tax Treaty Disputes
Taxpayers' Council rules again on compatibility of Brazil's CFC rules with tax treaties
Report on Attribution of Profits to PEs released
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
Court decision on pre-2004 thin capitalization rules
Unify Your Processes
Simplify Compliance
Empower Your Team