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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
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
