Tag: OECD conventions
Transfer pricing regulations are not valid to discuss the deductibility of expenses incurred vis-à-vis third parties
09/15/2026
In a groundbreaking ruling, the Supreme Court concludes that the tax authorities cannot use transfer pricing regulations to deny the deduction of expenses that a Spanish company has incurred with third parties, even if the underlying business decision has been taken by the group. In recent years, there have been numerous cases in which the […]
Three recent resolutions of the Central Economic-Administrative Court establish criteria in relation to the taxation of artists and athletes
04/08/2025
The international taxation of artists and athletes has been the subject of analysis and discussion for many years, affecting issues as diverse as tax residence, the delimitation of income that can be classified as “artistic” or “sports” or the development of the activity through companies. This type of income is specifically regulated in Article 17 […]