Author: Patxi Arrasate Roldán
What changes in Pillar 2 after the introduction of the new OECD Safe Harbours
The OECD proposes new permanent safe harbours with the aim of simplifying the standard calculation rules of the Global Complementary Minimum Tax (Pillar 2) and reducing the possibility of an obligation to pay tax on this tax. In addition, it proposes the extension of the existing transitional CbCR safe harbour for one year. On 5 […]
The Spanish rules on withholding taxes on dividends paid to foreign shareholders are contrary to EU law
According to the Court of Justice of the European Union, the Biscayan rules on non-resident income tax grant different treatment to withholdings borne by national shareholders as compared with those borne by non-resident shareholders, which is contrary to the Treaty on the Functioning of the European Union. The distribution of a dividend by a company […]
Minimum 15% Global Tax: new steps on the most relevant tax measure of recent years for large Groups of Companies
Minimum 15% Global Tax: new steps on the most relevant tax measure of recent years for large Groups of Companies Among other provisions, the Bill contemplates a very strict penalty regime, establishing fixed fines of 10,000 euros for each data point or set of data that should have been included in the declaration (in cases […]