Author: Nicolás Cremades Leguina
The public CbC: first application in Spain of the new obligation of “corporate transparency”
The obligation to publish the so-called “country-by-country report” (known as “public CbCR”) affects multinational groups and independent companies whose consolidated revenues exceed 750 million euros in each of the last two consecutive years. Spain has some relevant peculiarities in the transposition of this obligation that should be considered in its first application. Information on corporate […]
The Spanish participation exemption on dividends and capital gains is a “full exemption” for the purposes of the Controlled Foreign Company regime
According to the Directorate General of Taxes, exempt dividends and capital gains obtained by foreign holding companies do not have to be declared in Spain. Controlled Foreign Company (CFC) regimes are traditionally anti-abuse rules aimed at avoiding the deferral of taxation of income – normally of a “passive” or non-business nature – in controlled foreign […]