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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.
Manuel PeñÃn Aláez
Apr 24, 2026
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.
Manuel PeñÃn Aláez
Apr 24, 2026
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.
Manuel PeñÃn Aláez
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.
Manuel PeñÃn Aláez
Apr 23, 2026
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 MartÃn
Mar 24, 2026
Insights
Tax
Repeal of RDL 2/2026: tax impact on Corporate Income Tax and VAT in Spain
Analysis of the repeal of RDL 2/2026 and its tax impact on Corporate Income Tax, VAT measures, and tax incentives for businesses in Spain.
Teresa MartÃn
Mar 20, 2026
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
Insights
Tax
OECD Pillar Two update: Side-by-Side Package and new GloBE safe harbours
The OECD Side-by-Side Package introduces new Pillar Two safe harbours, including the Simplified ETR Safe Harbour and Substance-Based Tax Incentives Safe Harbour, aimed at simplifying GloBE compliance and strengthening legal certainty for multinational groups.
Pablo Pascual Garrido
Mar 16, 2026
Insights
International Taxation
Beckham Law and relocation to Spain with requirements for directors, RETA, and DGT criteria
The Beckham Law (Article 93 of the IRPF Law) allows individuals relocating to Spain for employment reasons to be taxed under the Non-Resident Income Tax regime for six years. We analyze the requirements when the relocation is linked to appointment as a director, the limits relating to permanent establishments and holding companies, and the DGT’s criteria on RETA, related-party relationships, and changes to senior management employment.
Marcela González
Jan 28, 2026
Insights
International Taxation
TSJ Madrid on primary residences under the Beckham regime
The High Court of Justice of Madrid confirms that the primary residence of taxpayers under the Beckham regime does not generate imputed real estate income, by applying the referral in Article 85 of the Personal Income Tax Law to expatriate workers.
Isabel Robledillo
Dec 1, 2025
Insights
Tax advice for businesses
The Constitutional Court rules on the method used to calculate corporate income tax prepayment for large companies
The Constitutional Court has dismissed the question of unconstitutionality regarding installment payments for corporate income tax by large companies, considering their calculation based on accounting results to be reasonable.
Isabel Robledillo
Dec 1, 2025
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