Publications - Tax
Transfer pricing: it is not correct to adjust results to the median when there are no comparability defects
In a particularly significant judgment on the subject of transfer pricing handed down on March 6, 2019, the National Appellate Court concluded on economic comparability analyses, and in particular, on selection of the point in the range of values…
Tax Newsletter - April 2019
Supreme Court confirms discriminatory tax treatment to non-Spanish resident mutual funds
In a judgment dated March 27, 2019, the Supreme Court established that the justification for restrictions on the movement of capital may only be held valid if set out in the law.
Tax Newsletter - March 2019
PTA clarifies some amendments introduced by the SIMPLEX + Program
Ruling no. 30211, of 15 March, was disclosed by the Portuguese Tax Authorities, clarifying the extension of some amendments introduced in the Portuguese VAT Code by the Decree-Law no. 28/2019, of 15 February, under the SIMPLEX + Program.
The stamp tax base on mortgage loan modifications is limited to the value of the modified aspect
Certain novations of mortgage loans are exempt from stamp tax, particularly those cases where only the interest rate and/or the repayment period are modified. However, where other financial clauses are amended, stamp tax does apply.
DIAN issues a reminder of the mandatory deadlines for renewing the registration of not-for-profit entities for the purposes of the Special Tax Regime
The Directorate of National Taxes and Customs (DIAN) recently issued a reminder to taxpayers of the deadlines - established in Decree no. 2442 of December 27, 2018 issued by the Ministry of Finance - by which not-for-profit entities (ESAL) and…
SIMPLEX + program approves new invoicing rules
Decree-Law no. 28/2019, of 15 February, was officially published, within the framework of the SIMPLEX + program, in order to promote the dematerialisation and reduce over-bureaucratisation in the emission and archiving of invoices, namely,…
CIT - Special Payment on Account to be paid until the end of March
The deadline to deliver the special payment on account (“PEC”) regarding fiscal year 2019 ends on 31 March for taxable persons resident within the Portuguese territory engaged primarily in a commercial, industrial or agricultural…
These are Spain's measures to prepare for a no-deal Brexit in the fields of employment, judicial cooperation, financial services and customs
The Spanish government has adopted a range of contingency measures to prepare for the event of the United Kingdom leaving the European Union without an agreement on March 30, 2019. They are temporary measures approved through Royal Decree-Law 5/2019…
CJEU rules on withholding tax exemptions under the Parent Subsidiary and the Royalty and Interest directives
The Court of Justice of the European Union (CJEU) has rendered two judgments that bring significant elements for interpreting the Parent Subsidiary Directive (PSD) and the Royalties and Interest Directive (RID). Both judgments were rendered on…
Tax Newsletter - February 2019