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
