Publications - Tax
It has been amended the transfer pricing regime and the transfer pricing file obligations
Law no.119/2019, 18 September, was officially published, which amends, among others, the transfer pricing regime, namely articles 63, 130 and 138 of the Corporate Income Tax (“CIT”) Code, which establish the transfer pricing regime, the…
It was published the first amendment to the Portuguese SIGIs’ Regime
On the 4th of September 2019, Law no. 97/2019 was published in Portugal’s Official Journal introducing the first amendment, approved under a parliament review, to the Real Estate Investment and Asset Management (SIGIs) regime,…
The U.S. Senate gives the green-light to the Protocol to amend the tax treaty between Spain and the U.S.
After being stalled for a number of years by an objection raised by Senator Rand Paul, on July 16 the U.S. Senate issued the Resolution of advice and consent to ratification of the Protocol amending the tax treaty between Spain and the U.S…
The deadline for the IES submission has been extended to 17 July 2019
Order no. 271/2019.XXI, of Secretary of State for Tax Affairs, was published in the Tax Authorities' website, which extends the deadline of the Annual Accounting Information (“IES”) submission regarding fiscal year of 2018, ended in…
The Spanish tax authorities open the public comment phase of the transposition of the EU Directive on administrative cooperation in the field of taxation (DAC 6)
On Thursday, June 20, 2019, the State Tax Agency published the regulatory texts, proposed by the Directorate-General of Taxes, transposing into Spanish law Council Directive (EU) 2018/822 of 25 May 2018 as regards mandatory automatic exchange of…
The European Commission initiates an infringement proceeding against Spain due to form 720
On Thursday, June 6, 2019, the European Commission decided to refer Spain to the Court of Justice of the European Union for “imposing disproportionate penalties on Spanish taxpayers for the failure to report assets held in other EU and EEA…
Mexico puts an end to tax amnesties
The Official Journal of the Federation has published a decree annulling the remission of taxes owed by tax debtors.
Mexico establishes new penalties for taxpayers that issue tax receipts to justify simulated transactions
On May 16, 2019, the government published in the Official Journal of the Federation the Decree reforming article 113.III and adding an article 113.bis to the Federal Tax Code, in order to reinforce the measures being taken against the purchase and…
Transfer pricing: it is not correct to adjust results to the median when there are no comparability defects
In a particularly significant judgment on the subject of transfer pricing handed down on March 6, 2019, the National Appellate Court concluded on economic comparability analyses, and in particular, on selection of the point in the range of values…
Supreme Court confirms discriminatory tax treatment to non-Spanish resident mutual funds
In a judgment dated March 27, 2019, the Supreme Court established that the justification for restrictions on the movement of capital may only be held valid if set out in the law.
PTA clarifies some amendments introduced by the SIMPLEX + Program
Ruling no. 30211, of 15 March, was disclosed by the Portuguese Tax Authorities, clarifying the extension of some amendments introduced in the Portuguese VAT Code by the Decree-Law no. 28/2019, of 15 February, under the SIMPLEX + Program.
The stamp tax base on mortgage loan modifications is limited to the value of the modified aspect
Certain novations of mortgage loans are exempt from stamp tax, particularly those cases where only the interest rate and/or the repayment period are modified. However, where other financial clauses are amended, stamp tax does apply.