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Advisers say Spanish taxpayers will have to reexamine how they finance themselves following TP litigation that went all the way to the country's Supreme Court
Spain levies a net wealth tax on the net assets of individuals for the purposes of which any individual owning assets located, or rights which can be exercised, in a Spanish territory is classed as a taxable person by virtue of an in rem obligation.
A recent Portuguese Arbitration Court decision (Case 639/2017-T), dealing with the application of the exemption method to foreign-based liquidation proceeds for non-habitual tax residents serves as a good illustration of how this domestic exemption works.