Exemption versus foreign tax credit relief

Posted on Posted in Publications, Tax

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 […]

The special tax regime for Spanish holding companies

Posted on Posted in Company Law, Publications, Tax

A Spanish Holding Company   is a standard company, that is, a private limited company (“SL”) or public limited company (“SA”), which include in its business purpose, among others, the management of foreign subsidiaries. In this post, I   will refer to these companies as ETVE’s for their Spanish Acronym Entidad de Tenencia de Valores Extranjeros. Upon […]

Controlled Foreing Corporation (“CFC”) new rules in Spain for 2015

Posted on Posted in Publications, Tax

Overview Controlled Foreign Corporation (“CFC”) rules target profit shifting strategies, whereby easily mobile income is attributed to group companies located in low tax jurisdictions. The Action 3 of the Plan on Base Erosion and Profit Shifting (“BEPS”) directed the OECD   is specifically devoted to this important issue. Spain has become one of the early adopters […]

Corporation Tax

Posted on Posted in Publications, Tax

The main features of companies taxation in Spain for 2012 are the following: Effective 2012 a Spanish company  will be subject to a corporation tax rate of 30 %. However a reduced tax rate of 25 % may apply for small companies (turnover under EUR 10 Millions). The reduced tax rate is applicable to a […]