Spain–MNE Tax

Asia-Pacific

OECD releases report assessing tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

October 22, 2020

The OECD today released stage 2 peer review reports that assess compliance with global minimum standards on cross-border tax dispute resolution . . .

Europe

The economics of leasing and the arm’s length standard

October 9, 2020

Dr. Harold McClure, an New York City economist, presents a model of what would compensate arm’s length lease payments and applies this model to ship leasing . . .

Digital Economy

Spain’s upper house passes financial transactions tax, digital services; both taxes to go into effect in January: Cristina Enache / Tax Foundation→

October 8, 2020

Denmark

Spain must recover illegal state aid for tax lease schemes

September 30, 2020

Susi Baerentzen, Ph.D., Copenhagen, Denmark, discusses the General Court of the European Union’s September 23 ruling in the Spanish tax leasing case, aka the Lico Leasing case, a long-running taxation state aid dispute that had been referred back from the European Court of Justice in 2018 . . .

Digital Economy

Spain aims to tax revenue of companies that provide communications services such as instant messaging and calls: Reuters→

September 15, 2020

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Americas

OECD to stick to digital tax negotiation timetable despite US opposition

June 18, 2020

The OECD today confirmed that it will continue its work developing a multilateral approach to the taxation of the digital economy before . . .

Americas

Spain says digital tax uses objective criteria, won’t discriminate against US MNEs: Reuters→

June 3, 2020

Americas

US to investigate digital services taxes in India, Brazil, Turkey, Indonesia, the European Union, five EU countries

June 2, 2020

The Office of the US Trade Representative (USTR) today announced that it has initiated an investigation into digital services taxes proposed or adopted in . . .

Digital Economy

Spanish government approves digital services tax targeting large multinationals

February 18, 2020

Dr. Patricia Lampreave, a professor at the Instituto de Estudios Busatiles, Madrid, discusses a bill for a digital service tax approved today by the Spanish government . . .

Europe

Spain to scrutinize taxpayers’ transfer pricing positions

February 17, 2020

Pilar Barriguete and Edland Graci, Duff & Phelps, Spain, discuss new Spanish guidance which describes the international tax and transfer pricing issues that the tax authorities will focus their enforcement efforts upon in 2020 . . .

Austria

Germany, France, Italy, seven others, supporting plan for EU tax on stock trades of a minimum of .2% of transaction value: Patricia Kowsmann / Wall Street Journal→

December 11, 2019

Belgium

Latest EU effort to make country-by-country reporting public fails

December 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland discusses a recent EU Council vote on a proposal to make public country-by-country reports on large multinationals . . .

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Americas

US announces entry into force dates for new tax treaty protocols with Japan and Spain

September 3, 2019

The US Treasury has announced that a protocol to the US-Japan tax treaty entered . . .

Americas

US Senate ratifies long-pending tax treaty protocol with Spain

July 17, 2019

The US Senate on July 16 ratified a protocol to the US-Spain tax treaty (Treaty Doc. 113-4), the first US ratification of a tax treaty or tax treaty protocol since 2010. The protocol . . .

Europe

Spanish appeals court rules on IKEA subsidiary’s approach to transfer pricing comparability, arm’s length range

June 24, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss the Spanish Court of Appeal’s decision earlier this year in IKEA, a transfer pricing case addressing the taxpayer’s application of the transactional net margin method (TNMM) . . .

Austria

EU loss in Polish State aid case may be a win for digital services tax

May 17, 2019

Leopoldo Parada of the University of Turin, Italy, discusses a May 16 EU General Court decision in Poland v. Commission which could have implications for the legality, under EU State aid rules, of unilateral European digital services tax measures . . . .

Africa

CIAT database reflects progress made by 15 countries implementing BEPS recommendations

August 9, 2019

In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .

Americas

US Senate Foreign Relations Committee approves tax treaty protocols with Japan, Luxembourg, Spain, Switzerland

June 25, 2019

Tax treaty protocols amending US tax treaties with Japan, Luxembourg . . .

Ten EU states considering German plan for .2% tax on purchases stock in EU headquartered companies: Reuters→

June 17, 2019

Europe

EU court rules on deductibility of losses of sub-subsidiary, losses transferred through merger

June 24, 2019

Davide Anghileri of the University of Lausanne discusses two ECJ decisions released June 19 addressing when EU States are required by EU law to allow a parent company to deduct in Sweden final losses of a group member; one case involved losses of a sub-subsidiary located in Spain and the other of a Germany subsidiary later merged into its Swedish parent . . .

Asia-Pacific

New Japan-Spain tax treaty signed

October 17, 2018

Japan and Spain have signed a new tax treaty, the . . .

EU tax on tech firm revenue does not target US companies, Moscovici asserts

April 20, 2018

The EU’s proposed digital services tax is not aimed US tech companies; rather, the interim tax is designed to level the playing field for all businesses wherever located, Pierre Moscovici, EU Commissioner . . .

Europe

EU Advocate General clarifies when sub-subsidiary losses are final for tax deduction

January 18, 2019

Davide Anghileri of the University of Lausanne discusses the EU Advocate General’s January 10 opinion in the Holmen case . . .

Europe

Spain applies MLI to 86 tax treaties, opts for mandatory binding arbitration: EY→

June 15, 2017

Spanish tax lease system is State aid, European Court of Justice rules

July 27, 2018

Davide Anghileri of the University of Lausanne discusses a European Court of Justice decision rendered July 25 holding that the Spanish tax lease system constitutes State aid and thus overturning a ruling of the EU General Court . . .

Digital Economy

Spanish government proposes digital services tax

October 24, 2018

Alma Virto, a Ph.D. candidate at the University of Salamanca, writes that Spain’s Council of Ministries on October 19 proposed a digital services tax on large tech companies . . .

Africa

Twenty nations’ tax laws may aid multinational profit shifting, OECD report says

October 17, 2017

Twenty countries have tax laws that may be considered harmful preferential regimes, facilitating tax avoidance by multinationals and reducing the tax base of other countries, an OECD report released Monday revealed. The review, conducted by the OECD Forum on Harmful Tax Practices (FHTP), assessed countries’ tax laws against . . . .

Asia-Pacific

Japan, Spain to negotiate tax treaty amendments

April 24, 2017

The governments of Japan and Spain will begin negotiations to amend their existing tax treaty, Japan’s Ministry. . .

Africa

New CIAT database tracks BEPS implementation in 36 countries

February 22, 2019

The Inter-American Center of Tax Administrations (CIAT) on February 21 released . . .

Africa

US negotiating exchange of country-by-country tax reports with 20 more nations

August 30, 2017

The US IRS is negotiating with 20 countries to annually exchange country-by-country reporting data on large multinational firms . . .

Europe

Spain, Britian sign Gilbraltar tax treaty: Aaj News→

March 7, 2019

Digital Economy

Spain to propose digital services tax beginning 2019

May 9, 2018

The Spanish government has announced it will propose a temporary tax on digital company revenue this year, aiming for the new tax to take effect in 2019, writes Alma Virto. a researcher and PhD candidate at the University of Salamanca, Spain . . .

Europe

Spain publishes tax form to disclose transactions with related-parties, tax havens

September 4, 2017

Spain’s Ministry of Finance and Public Administration has approved and published a new informative tax return for the disclosure of related-party transactions and transactions . . .

Americas

US agrees to exchange country-by-country tax reports with Spain, announces effective dates of Malta and Guernsey agreements

December 21, 2017

The US has signed a competent authority agreement with Spain to exchange country-by-country tax reports on multinational firms, the IRS announced December 20. The IRS also announced the effective dates of competent authority agreements signed with Malta and Guernsey. All three . . .

Europe

Spanish firm Euskaltax joins Andersen Global

November 16, 2017

Andersen Global, an international association of legally separate, independent member firms, on November 13, announced that it has entered into a collaboration . . .

Algeria

Spain appeals EU General Court’s finding of State aid in goodwill tax scheme

March 28, 2019

Spain has appealed to the Court of Justice of the European Union seeking to overturn judgments . . .

Americas

Australia may exercise transfer pricing reconstruction power, will change approach to allocation of risk, official says

August 22, 2018

The Australian Taxation Office has not yet used its sweeping power to reconstruct transactions for transfer pricing purposes; however, that may soon change, Australian Deputy Commissioner Mark Konza said at the Tax Institute’s 2018 National Transfer . . .

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin