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 […]

Interest on related party debt disallowed for tax purposes

Posted on Posted in Publications, Tax

  Interest on related – party debt would be disallowed for tax purposes when the funds borrowed are used to finance investments in other group companies (contributions to capital) or to internal acquisitions (i.e. acquire shares of a group company from other group company). This anti-fraud measure aims to tackle the recent abuses of multinational […]