Spain: The limitation on the offsetting of tax losses and the use of double taxation credits for large companies is again reduced and other tax modifications are introduced
Among others, a tax is created on the margin of interest and commissions of certain financial institutions, the savings tax rate is increased in the Personal Income Tax for taxable income over EUR 300,000 and an exemption is introduced for Personal income tax and Inheritance and Gift tax purposes in relation to donations made by employers to their employees to alleviate the damage caused by the DANA. In addition, the cases in which the reserve for investments in the Canary Islands can be used are extended.Portugal Indirect Taxes Newsletter - N.º 2
This edition covers key indirect tax developments in Portugal in the last months, especially regarding the postponing, from 2024 to 2025, of the extraordinary use of PDF invoices as electronic invoices and the Stamp Duty framework of financial operations carried out between branches and their headquarters.Reflections on expert evidence in tax proceedings
In recent rulings related to the deduction for R&D&i in Corporate Income Tax and for Hydrocarbon Tax, the Supreme Court offers important reflections on the value of expert evidence in tax proceedings and on the value of reports issued by officials of the Tax Administration itself.The Supreme Court of Spain delimits the binding scope of the reasoned report for the R&D&I deduction
The Supreme Court has confirmed that the reasoned reports are binding on the tax administration both in the classification of the activity and in the quantification of the basis for the deduction for tax years started before 2015. However, the issue is still open to discussion for deductions generated after that date, as pointed out in a recent ruling by the TEAC.First State and Autonomous Community tax measures to support those affected by the DANA (and others that could be considered)
The State and Autonomous Community governments affected by the DANA that occurred between 28 October and 4 November 2024 have approved various tax measures aimed at alleviating the economic costs and formal obligations of those affected in these first months. We review the main measures already approved and propose others that could be considered.