Interest on equity paid by Brazilian companies to their Spanish shareholders

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Brazilian companies can compensate their shareholders both with dividends or paying interest on their equity (“juros”). The former is, under certain conditions set out in the Federal Law 9249 of December 26, 1995, deductible for the Brazilian paying company. This post is about the taxation of interest on equity paid by Brazilian companies to their […]

Tax treaties of Spain

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Spain has a broad network of Tax Treaties. As the date of this post, the list of Tax Treaties is the following:   Spain Tax Treaty Network Albania East Timor Kuwait Saudi Arabia Algeria Ecuador Kyrgyzstan Senegal Andorra Egypt Latvia Serbia Argentina El Salvador Lithuania Singapore Armenia Estonia Luxembourg Slovakia Australia Finland Macedonia Slovenia Austria […]

Exemption versus foreign tax credit relief

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How to avoid double taxation on foreign source dividends In Spain, double taxation of foreign source dividends can be avoided by the two classic system: the participation exemption or the foreign tax credit relief (i.e. the imputation system). The exemption system is applicable under certain conditions, namely, a participation in the foreign subsidiary of, at […]