Spain’s National Court challenges the deductibility of intragroup services in the absence of a written contract
Pilar Barriguete and Victoria Arozamena, Kroll Advisory, S.L., discuss Spain’s recent tendency to challenge intragroup services, denying its corporate income tax deductibility; this view is most recently reflected in the Spanish National Court’s January 25 ruling that it did not consider the provision of intragroup services to be sufficiently proven in the absence of a written contract.