Garrigues Spain

Rafael Calvo Salinero and Fernando Brioso de la Rica of Garrigues examine the implications of a Spanish Supreme Court ruling on treaty relief when the Interest and Royalties Directive exemption is denied

Rafael Calvo and Adrián Arroyo of Garrigues Madrid discuss a National Court judgment clarifying that interest on equity (JSCP) received from Brazilian entities qualifies for an exemption under the Spain–Brazil double tax treaty

Nicolás Cremades and Inés Mora-Figueroa of Garrigues detail the impact of the Spanish participation exemption regime’s modification on the controlled foreign company regime, and how a Directorate General of Taxes ruling has enhanced clarity