Publications - Tax
Real Estate leasing is an economic activity even when management is outsourced, according to the Directorate General of Taxes
According to the most recent criterion of the Directorate General of Taxes (DGT), real estate leasing can be classified as an economic activity for Corporate Income Tax purposes when managed by specialized experts who have been subcontracted, even…
Tax Newsletter - June 2024
We analyze the main news, judgments, resolutions and regulations in the latest issue of the Tax Newsletter.
Spain: Minimum 15% Global Tax: new steps on the most relevant tax measure of recent years for large Groups of Companies
Contrary to the criteria previously maintained by some regional economic-administrative courts and the DGT, it is now concluded that, if contributions to equity are not taken into account when computing the increase in equity that gives the right to…
Spain: The General Directorate of Taxes (DGT) clarifies that capital reductions with return of contributions have no impact on the capitalization reserve
En contra del criterio que venían manteniendo algunos tribunales económico-administrativo regionales y la DGT, se concluye ahora que, si las aportaciones a los fondos propios no se tienen en cuenta para computar el incremento de los fondos propios…
Tax Newsletter - May 2024
We analyze the main news, judgments, resolutions and regulations in the latest issue of the Tax Newsletter.
China: Dealing with the future tax administration on enjoying treaty benefit for preferential tax rate on dividends
Under China's tax laws, non-resident companies generally face a 10% tax on China-sourced dividends, but avoidance of Double Taxation Treaties with countries like Spain or France can reduce this to 5% if specific conditions are met. These companies…
Tax Newsletter – April 2024
We analyze the main news, judgments, resolutions and regulations in the latest issue of the Tax Newsletter.
This is the Artificial Intelligence Strategy in the Strategic Plan of the Spanish Tax Agency
El Plan Estratégico de la Agencia Tributaria española establece los principios que deberán guiar el uso de la inteligencia artificial para la prevención y lucha contra el fraude fiscal. Se echan de menos, no obstante, referencias expresas a derechos…
Garrigues Sustainable Newsletter - April 2024
In this newsletter we compile the most relevant legal news on ESG matters in Spain, published by Garrigues.
Peru: The deadline is approaching for Peruvian consortia, funds and trusts to submit the declaration of ultimate beneficial owner
Any Peruvian or foreign company or investor who directly or indirectly participates in the results or exercises effective control of the legal arrangement shall take into account the declaration to be made within the first 20 days of July 2024.
Tax Newsletter - March 2024
We analyze the main news, judgments, resolutions and regulations in the latest issue of the Tax Newsletter.
Spain: Time of imputation of refunds of taxes declared unconstitutional
The Spanish Constitutional Court has been limiting the temporal effects of the unconstitutionality of tax rules, in the case of non-consolidated situations, to the date on which the corresponding ruling is handed down, with an expansive…