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Insights Tax
The Supreme Court Limits the Use of Transfer Pricing Against the Tax Authorities
A key ruling for companies undergoing restructuring: transfer pricing only applies between companies within the same group and cannot be used to deny tax deductibility of expenses incurred with third parties.
Adria Lizondo Jun 29, 2026
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Insights Tax
Can the Spanish Tax Agency fine you if you incorrectly reported your foreign income?
The Supreme Court clarifies when the Spanish Tax Agency cannot fine taxpayers who applied the exemption certified by their employer while working abroad, even if it was later found not to apply.
Adria Lizondo Jun 29, 2026
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Insights Tax
Spanish Tax Agency Updates VAT and VERI*FACTU Guidance: Third-Party Invoicing and Marketplace Models
Spain's AEAT updates its INFORMA entries on VAT and VERI*FACTU. We analyse binding ruling V0650-26 and its impact on third-party invoicing in marketplaces and RRSIF compliance.
Adrià Lizondo Jun 29, 2026
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Find out about the latest developments that could affect your business.
Insights Transfer Pricing
OECD reviews transfer pricing rules for intra-group services: what multinationals need to know
The OECD has launched a public consultation to revise its transfer pricing guidance on intra-group services (Chapter VII). Find out what changes for the benefit test, low value-adding services and documentation requirements for multinational groups.
Adrià Lizondo Jun 29, 2026
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Insights Tax advice for businesses
Capital gains exemption in Corporate Tax applicable to earn-out in share sale transactions
Key insights on capital gains exemption, Corporate Tax Spain, and the earn-out taxation in share transfer transactions based on Spanish Tax Authorities criteria.
Toni Sánchez Apr 28, 2026
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Insights Tax
Spanish DGT limits main residence tax exemption for non-resident over-65 sellers
The Spanish DGT clarifies the over-65 home sale exemption and its limits for non-resident taxpayers, analysing IRPF vs non-resident tax and capital gains taxation in Spain.
Apr 24, 2026
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Insights Tax
Public CbCR in Spain: ICAC guidance, deadlines and compliance for multinational groups
Overview of public CbCR in Spain and ICAC guidance, focusing on multinational groups, reporting obligations, and publication deadlines under EU regulations.
Apr 24, 2026
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Insights Tax
Tax treatment of rent-back transactions with purchase option according to the DGT
The Spanish Tax Authorities (DGT) clarify when sale and leaseback transactions are treated as financing and do not generate taxable income for Corporate Income Tax purposes.
Apr 24, 2026
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Insights Tax
VAT pro-rata according to the TEAC and limits for its modification outside the deadline
The TEAC clarifies that VAT pro-rata cannot be modified outside the filing deadline and sets criteria for the treatment of real estate transactions in its calculation.
Apr 23, 2026
150 BUILDINGS
Insights Tax
International double taxation on dividends: new Madrid High Court criterion in Personal Income Tax
Analysis of the new Madrid High Court ruling on international double taxation on dividends, its impact on tax deductions and foreign withholding taxes.
Teresa Martín Mar 24, 2026
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Insights Tax
Tax Control Plan 2026: AEAT priorities, tax risks and new compliance obligations
Spain’s 2026 Tax Control Plan strengthens tax control, digitalization and anti-fraud measures. Key insights on risks, compliance and new obligations for businesses.
Fernando Cuevas Mar 20, 2026
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