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Francisco Lavandera As is widely known, Spain recently implemented a major tax reform, mainly focused on corporate income tax. But domestic situations are not the only ones affected by the new set of provisions. Certain rules with international tax implications have also experienced substantial changes which are likely to have an effect on the way inbound investments are structured. The most remarkable change is the extension of the existing participation exemption rules – hitherto confined exclusively to shareholdings in foreign entities – to domestic subsidiaries. Although Spanish-source dividends already enjoyed full exemption under certain conditions, the new framework allows for the tax-free treatment of capital gains arising from share disposals in a purely domestic context.

While Sweden may be seen as effectively preventing base erosion through limiting interest deductions, the effects on businesses and investments must be carefully scrutinised before being considered in other countries, argue Hussein Abdali and Tord Fredriksson of Grant Thornton.

May’s instalment of his column sees Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, look at the problems that may arise for taxpayers given the timing differences applicable for different documentation and reporting requirements, and what options are available for reconciling these.

Mark Lindley, head of tax at the Qatar Financial Centre (QFC), looks at investment opportunities across the Gulf Cooperation Council (GCC) as the region moves away from a reliance on oil and prepares to host global events like the FIFA World Cup. He also tackles the resultant controversy concerns that could lead to tax disputes.

Bob van der Made With the fight against aggressive tax planning, tax fraud, tax avoidance and tax evasion having become a policy priority for the EU, the European Parliament is upping the ante in the heated debate on tax rulings and calls for more tax transparency. On February 12 2015, the European Parliament decided to set up a special committee on tax rulings and other measures similar in nature or effect (TAXE) "to examine practice in the application of EU state aid and taxation law in relation to tax rulings and other measures similar in nature or effect issued by member states, if such practice appears to be the act of a member state or the Commission". The special committee's mandate is therefore to analyse and examine how EU state aid rules have been applied by the Commission to tax rulings in member states since January 1 1991 (this seems inspired by the Commission's ongoing state aid investigation into Apple; otherwise this date seems arbitrary), and member states' compliance with the EU's directives on mutual assistance (1977) and on administrative cooperation in tax matters (2011), in particular with regard to the spontaneous exchange of information on tax rulings. It should be noted, however, that member states are only effectively obliged to spontaneously exchange information on cross-border tax rulings under certain circumstances under the EU Directive on administrative cooperation in tax matters since 2013. According to the Commission's statistics, member states haven't actually really done this in practice, however.

Loreto Pelegrí

Khoonming Ho

Alexander Linn

Another month, another series of attacks on multinationals' tax affairs. In Australia, Apple, Google and Microsoft gave evidence to a Senate hearing looking into their transfer pricing, before resource companies BHP Billiton and Rio Tinto took the stand.

The introduction of the UK's diverted profits tax (DPT) on April 1 2015 has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) it seemed intended to appease public anger at multinationals failing to pay their 'fair share' of tax. It has been roundly criticised for its breadth and complexity, for the speed with which it has been introduced, for the lack of public consultation and parliamentary scrutiny, and for pre-empting the multilateral response to tax avoidance of the G20/OECD BEPS Project. DLA Piper's Stephen Jones asks whether the DPT has created a cloud of uncertainty to cover the previous decade’s climate of reform favourable to global business.