Interest on equity paid by Brazilian companies to their Spanish shareholders

Posted on Posted in Publications, Tax

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

Posted on Posted in Publications, Tax

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 […]

Internal dealings involving a branch in Spain

Posted on Posted in Publications

The recent overhaul in the Spanish Tax system has introduced several new rules whose consequences are still to be analyzed. I am writing today about an apparently innocuous change in arm’s length rules applicable to the internal dealings between a foreign entity and their Spanish branches or, more generally, Permanent Establishments. Before the Law changed, […]