![]() Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.Īll rights reserved. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. (Jano) Bustos | Isabel Hidalgo | information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. Araceli Saenz de Navarrete Crespo | Iñigo Alonso Salcedo | Tatiana de Cubas Buenaventura | & Young LLP (United States), Spanish Tax Desk, New York.EY Spain will be involved in the preparation and submission of observations to the Spanish Tax Authorities.įor additional information with respect to this Alert, please contact the following: Ernst & Young Abogados, Madrid The draft Resolution is now subject to public consultation until 26 November 2019. ![]() Given the lack of conclusive guidance on the characterization of foreign entities as look-throughs under Spanish rules, the criteria included in this draft Resolution will provide additional certainty on how to approach foreign look-through vehicles for Spanish tax purposes.Īlso, the fact that the Spanish approach will be aligned with that of the OECD will help prevent mismatches and ensure a more coordinated treatment at an international level.
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