Tax
The Tax Administration must give individual reasons for the subjective element in order to derive tax liability
A recent decision of the Regional Economic-Administrative Court of the Principality of Asturias (Spain) insists on the importance of motivating the guilt or negligence of the de facto or de jure directors, in order to derive liability for the infringements committed by the administered company.Three recent resolutions of the Central Economic-Administrative Court establish criteria in relation to the taxation of artists and athletes
The international taxation of artists and athletes has been the subject of analysis and discussion for many years, affecting issues as diverse as tax residence, the delimitation of income that can be classified as “artistic” or “sports” or the development of the activity through companies.The hearing procedure is essential when the settlement or penalty proposals are rectified
According to the case law of the Supreme Court, it is necessary to offer a new hearing when a proposal to impose a penalty is rectified (even to reduce it), so that its omission determines the nullity of everything that has been done. The Audiencia Nacional has already concluded in the same way when it is a question of rectifying a settlement proposal.The DGT stresses the concept of autonomous economic unit in relation to indirect taxation in the hotel sector
Indirect taxation on the acquisition of hotels in Spain is in a state of considerable legal uncertainty, despite the numerous binding rulings of the Directorate General of Taxes (DGT) which reiterate a solid and long-standing criterion.Mexico: Bill submitted to tax inheritances and donations exceeding 15 million pesos
On March 4, 2025, a bill was submitted to the Congress of Mexico City, proposing a decree to amend the Income Tax Law (ISR). The bill seeks to modify Articles 93, 130, and 132, as well as to add a new article 132 bis, with the objective of imposing progressive tax rates ranging from 10% to 30% on all income derived from donations, inheritances, and bequests exceeding 15 million pesos.Key Points on Portugal's IFICI Tax Incentive for Scientific Research and Innovation Activities
Since 2024, Portugal's IFICI tax incentive has provided a preferential tax regime for individuals engaged in scientific research and innovation. However, its implementation is highly complex due to scattered regulations, multiple eligibility categories, and intricate registration and verification procedures. This guide breaks down the key aspects of the regime, including eligibility criteria, tax benefits, registration requirements, and important deadlines for beneficiaries.China: The State Administration of Taxation expands the circumstances of issuing Tax Residency Certificate
The Chinese current rules allow issuing a Tax Residency Certificate solely for claiming tax treaty benefits. While this is the primary purpose, there are various legal, financial, and regulatory reasons for Chinese tax residents to provide this certificate abroad. Effective April 1, 2025, the new rules will broaden the circumstances for issuance, benefiting outbound investments by Chinese investors, foreign-invested companies, and foreign individuals.