02 Jan, 2025 CJEU finds Spanish withholding tax rules applicable to non-resident loss-making investors are contrary to EU right to free movement of capital By Maria Mera Álvaro Fernández Carmen Delgado The Court of Justice of the European Union (CJEU) has recently issued a judgment (Case C-601/23) on the entitlement of a non-resident...
18 Jan, 2023 Developments in Spanish tax exemptions for sovereign investors: impact for M&A deals and tax disputes By Álvaro Fernández Silvia Paternain Bosco Montejo The domestic Spanish tax code does not, of itself, provide for any specific exemptions or favourable regimes for foreign sovereign...
06 Jul, 2021 Parent-subsidiary exemption: Spanish court recognises its application to a Luxembourg holding company By Silvia Paternain Bosco Montejo Álvaro Fernández The Spanish National High Court (‘the High Court’) has issued a judgment (‘the judgment’) on the entitlement of a non-resident taxpayer...