On 28 January 2026, the Spanish Central Economic-Administrative Tribunal (TEAC) issued a unification decision (00/09964/2023/00/00) that clarifies, in unequivocal terms, the legal boundary between two distinct anti-avoidance doctrines that have
Spain’s “Beckham Law” was designed to attract international talent. But in practice, it has evolved into something more fragile: a regime that can be lost not only through obvious breaches,
With the 31st January UK tax return deadline fast approaching, thousands of British nationals living in Spain face a question that appears deceptively simple. Where are you tax resident? For
Determining your UK tax residency status is the cornerstone of managing your tax affairs effectively. Whether you’re an internationally mobile professional, relocating expat, or UK citizen working abroad, the Statutory
Spain’s “Beckham Law” (Article 93 LIRPF) remains one of the most attractive tax incentives in Europe for foreign professionals relocating to Spain. Named after the footballer who famously benefited from
When footballer Kylian Mbappé moved to Real Madrid, or when tech entrepreneur Daniel Ek relocated from Sweden to the UK, the media focused on transfer fees and business deals. But
Beckham Tax Rule vs Permanent Establishment Risk. For Digital Nomad workers and expats eyeing Spain’s attractive Beckham tax regime, there’s a critical question that could make or break your relocation
Over recent months, we have seen a growing number of UK taxpayers receiving letters from HMRC demanding payment of Spanish tax debts on behalf of the Agencia Estatal de Administración Tributaria (AEAT). In many of these
Spain’s Supreme Court has delivered two landmark decisions (STS 1372/2025 and STS 1402/2025) that fundamentally reshape how non-residents are taxed when they own significant assets in Spain. For the first
If you’ve been working from Spain while maintaining tax residence elsewhere, you might be surprised to learn that you could still owe Spanish taxes on that employment income. Spanish Non-Resident
A trust is a legal relationship originating in common law whereby a person (the settlor) transfers assets to another (the trustee) to hold and manage for the benefit of one
We are pleased to share that an article by Fernando Del Canto, “Why Private Wealth is the Next Tax Frontier”, has been published in Taxation magazine, the UK’s leading publication for tax professionals.
Your Guide to UK Travel and Immigration Changes. It is no secret that immigration regulations are always complex and understanding them, as well as keeping up to date with them,
Del Canto Chambers Spanish tax team, led by Paula Losada has recently achieved a significant victory against the Spanish Tax Authorities in an administrative court (Juzgado Central de lo Contencioso-Administrativo
Solidarity Tax on large fortunes: Key points for 2024. Last year saw the first application of the Solidarity Tax on Large Fortunes (ITSGF), which sparked considerable controversy and claims of
Yes, if you moved to Spain to run a business through a Spanish company as a director you may apply for the Beckham tax regime for a maximum of six
When it comes to obtaining Spanish residency as an investor (Golden VIsa) or a Digital Nomad, there are often numerous inquiries and uncertainties surrounding the process, especially in the case
International Tax Conference. After the successful completion of its first event in Belgrade, the International Tax Law Research and Policy Network (ITLRN) will host on September 29th, 2023, its second
Is it possible to buy or sell Spanish property from the UK and in pounds?. You might be under the impression that you can only buy Spanish property in Spain
Let your lawyer handle your financial and property affairs. A Power of Attorney will often be the most practical way of enabling a Spanish lawyer to undertake tasks and sign
Brits living in Spain go up by 9.5% in 2 years. In 2021, British nationals opting for Spanish residency increased by 4.4%, bringing the total number to less than 1%
Income Tax arrangements for internationally mobile employees. With a continuing increase in individuals working overseas temporarily, more employers are having to deal with the income tax situation for these mobile
Inheritance Tax and estate planning. UK real estate is always popular with overseas buyers, and investment continues to be made despite tax reforms over recent years. Before finalising a purchase,
Using a family investment company to pass on wealth. For families looking for a secure and tax-efficient way to manage and pass on wealth, a family investment company may offer
Global minimum corporate tax and impact on tax treaty shopping. The G7, and later the G20, met in June 2021 to sign a new tax agreement designed to stop multinational
Leon Fernando Del Canto has written an article in International Adviser looking at whether Brits who overstay in EU post-Brexit will face deportation. British tourists and second-home owners cannot exceed
Setting up a business in the UK. The UK has long been one of the best places in the world for setting up a business. Company formation and registration are
Taxation of british pensioners in Spain: British citizens applying for pensions while living in Spain: before and after Brexit implementation time. It is hard to trivialise the issue of pensions
Spanish and EU residents in the UK after Brexit. In the previous post about the European Union settlement scheme, established by the United Kingdom’s Withdrawal Agreement, we reviewed the timing
Global Analysis of Tax Treaty Disputes is a book that must be read. Eduardo Baistrocchi, author of this book and Associate Professor of Law in the London School of Economics
Gibraltar and its tax regime: more complexity in the negotiations of the Brexit Spain and the United Kingdom disagree on where to approach Gibraltar’s future fiscal status, whether within the
Gibraltar calls for more support against interference from Spain and the EU The Gibraltarian authorities ask the British government and the party of Theresa May for a greater commitment from
The Home Office changes the EEA (PR) Guidance Notes After media published that the Home Office tries to stop the applications to Permanent Residence Card from EEA citizens suggesting to
ISA Accounts: Effortlessly Save (tax) in the UK Individual Savings Accounts (ISA) are a very popular savings model in the UK. The fiscal will implement in April new fiscal measures
EU countries agree on taking a step forward on anti-avoidance rules The EU is about to approve a new Directive on anti-avoidance measures against third countries, the next step to
Del Canto Chambers: Universal jurisdiction and self-regulation to tackle tax fraud Our Managing Partner, León Fernando del Canto, has published an opinion piece in the Financial Instruments Tax & Accounting
Del Canto Chambers: fight against tax avoidance is key to restore confidence in tax system Our Managing Partner, León Fernando del Canto, has published a piece in the journal Bloomberg
The British government eases the inheritance tax regime Real estate wealth in the UK tends to concentrate generationally. The difficulties of young people’s access to this market influence their taxation.
Del Canto Chambers bets for Spain as British housing investments’ destination Our Managing Partner, León Fernando del Canto, has published statements in the British magazine Expat Network in which he
The EC keeps fining Apple for breaching the state aid regulations The EC in its report on Apple’s case accuses the company of enjoying a favorable tax treatment in Ireland
15-12-2016 | SPEAR’S Our Managing Partner, León Fernando del Canto, has published an opinion piece in the Spear’s magazine on the consensus necessity among professional international tax advisors and States
Del Canto Chambers advocates for the tax advisors’ leadership on the fight against fraud Our Managing Partner, León Fernando del Canto, has published an opinion piece in the Spear’s magazine
Gibraltar: the Brexit’s territorial problem Gibraltar advocates a distinctive agreement for the Rock and other British territories in the negotiations regarding Britain’s exit from the EU. Gibraltar’s Chief Minister, Fabian
Football Leaks: The tax evasión league A European consortium of investigative journalists uncover footballers and celebrities’ massive tax fraud, with an emphasis on Cristiano Ronaldo and José Mourinho. The German
Del Canto Chambers apuesta por la “jurisdicción universal” también para delitos fiscales Our Managing Partner, León Fernando del Canto, has published an opinion piece in the magazine Spear’s in which
Our Managing Partner, León Fernando del Canto, has published a statement in the economic journal Bloomberg BNA, in which he bets for the British tax authority to get wider powers
Our Managing Partner, León Fernando del Canto, has published an article entitled “Gibraltar: the yardstick of the future of Spanish and British relations” in The Barrister Magazine, where he analyses
17-11-2016 | THE BARRISTER MAGAZINE Our Managing Partner, León Fernando del Canto, has published an article entitled “Gibraltar: the yardstick of the future of Spanish and British relations” in The
British tax authority is targeting high-net-worth individuals in order to collect more taxes that patch the public deficit hole up. The United Kingdom has an economic problem: in 2015 its
09-11-2016 | BLOOMBERG BNA Our Managing Partner, León Fernando del Canto, has published a statement in the economic journal Bloomberg BNA, in which he bets for the British tax authority
The European Parliament debates a proposal to create a common base for corporate tax in the European Union. The European Commission has presented a proposal to the European Parliament to
Our Managing Partner, León Fernando del Canto, has published a statement in the journal Bloomberg BNA on the UK’s International Development Committee’s parliamentary report in which the British government is
Business leaders urge the government to improve the British taxation system and they see Brexit as a chance to simplify the fiscal model. The British tax system in need of
Non-domiciled in the United Kingdom are reshaping their properties and taxation schemes in anticipation of government’s taxation changes due to the Brexit. The British tax system and its rules will
The United Kingdom’s tax authorities investigate the offshore accounts of non-residents in their Overseas Territories and Dependencies upon US request. Last September the 30th, The British Treasury (HMRC -HER Majesty
Our Managing Partner, León Fernando del Canto, has published a statement in the magazine Bloomberg BNA where he comments on the last measures that HMRC has implemented to fight against
29-09-2016 | BLOOMBERG BNA Our Managing Partner, León Fernando del Canto, has published a statement in the magazine Bloomberg BNA where he comments on the last measures that HMRC has
The 31st of October marks the end of the Spanish Tax Agency’s Tax Inspection’s Intensified Action Plan against tax fraud, which has been described as arbitrary and confiscatory by the
The European Union is tax-tackling McDonald’s and demands that the fast-food company pay a huge to Luxembourg for back taxes, just as it did with Apple. The American fast-food giant
The economic journal Bloomberg BNA has published statements made by León Fernando del Canto in an article analyzing the fiscal situation faced by Apple in Europe after being sanctioned by
Our visit to London; the principle of universal jurisdiction in New York; the Apple Inc. case; and the revenue-raising antics by means of corporate tax employed by the Spanish government
Qatar, United Kingdom and #Apple kept us occupied at Del Canto Chambers this week At Del Canto Chambers, September has started with an interview in The Times regarding the #AppleTax
León Fernando del Canto on The Times: “Direct tax is a sovereign responsibility of individual EU states” The British journal The Times has published some statements of our Managing Partner
08-09-2016 | THE TIMES El diario británico The Times ha publicado unas declaraciones de nuestro Managing Partner, León Fernando del Canto sobre la reciente multa de 13.000 millones de euros
Our Managing Partner, León Fernando del Canto, has published in the prestigious British legal weekly journal Solicitors Journal (founded in 1856) an article on the fight against international tax avoidance
Profitability of the leading investment funds in Spain, business opportunities in the Middle East and the European Commission punishing Apple mark the end of the summer holidays. Over the past
HM Revenues & Customs proposals for sanctions against tax evasion, the BEPS project and Islamic finance have been the highlights of the week at Del Canto Chambers. International finance has
Gibraltar, especially in the context of Brexit, is set out to be an important player in the field of Family Offices. Its tax regime is not the only advantage; its
HMRC has an ambitious plan against tax evasion that is raising doubts among industry professionals and tax advisors. The British Treasury has launched a plan to prevent tax fraud which
This article will provide in- depth analysis on the measures that the OECD and the European Union are carrying out to combat international tax evasion. This week at Del Canto
The OECD is trying to resolve some of the classic international tax issues in the context of the digital economy. Welcome to the OECD 2.0 Since 2013 the OECD’s BEPS
The OECD leads an international project to fight tax fraud that places a special focus on cross-border taxation of corporate income tax. In economic terms, “globalization” means the same as
The Turkish government is completing in its parliament a tax amnesty to attract assets Turkey in the last years is conducting an adaptation process to international common standards on transparency
While in Europe markets are shrinking due to the Brexit, in the Middle East a new super-bank is being created which will start to operate in early 2017. Brexit, the
Tax havens do not exist. It is not me who says so, but the Secretary General of the OECD, Angel Gurria, who states that Panama “is the last major redoubt
¨In this interesting article published by The Guardian and written by Craig Scott, the author discusses the relevance, pros & cos of the Tax Mark launching as a reward for
An article in The Guardian by Simon Bowers reports that ‘the island should be ready to become independent, says senior minister after political attacks on finance industry.’ The full article
£2.9bn, the cumulative worth of the 92 league clubs in England and Wales for 2010/11, up 9% on the previous season. Deloitte’s Annual Review of Football Finance showed that despite
10/05/2012 – The OECD’s Task Force on Tax and Development, meeting in Cape Town, South Africa, has launched the concept of Tax Inspectors Without Borders/ Inspecteurs des impôts sans frontières – a
As reported by FC Business, Football League clubs took a huge step to self sufficiency when they agreed to the implementation of Financial Fair Play (FFP) regulations last week. Based
The average tax burden on earnings in OECD countries continues to rise Published in OECD Tax News – 25/04/2012 25/04/012 – The average tax and social security burden on employment
UK Tax Budget 2012 – The Association of Taxation Technicians has produced a Special Report on the March Budget in their April 2012 Newsletter. The full Report is detailed below: The contents of
As discussed in a number of previous Tax Alerts from www.venable.com, since 2009 the Internal Revenue Service has created three separate tax amnesty programs in order to encourage U.S. taxpayers
According to an article published by OECD on 28.03.12, at a meeting at OECD’s first Global Forum on Transfer Pricing tax, officials from 90 countries agreed on the need to
Aggressive tax planning – untaxed income, multiple deductions and other forms of international tax arbitrage – is a growing concern for all governments. OECD’s new report Hybrid Mismatch Arrangements: Tax
Tax Controversy and Dispute Resolution Alert Spain Supreme Court decision: Swiss principal has Spanish PE through its subsidiary in Spain. Read more below: https://www.internationaltaxreview.com/article/b1f7n5zmjj6xfq/spanish-supreme-court-anticipates-the-effects-of-the-beps-project
According to Andrew Goodall, at the Tax Journal, the UK’s corporate tax competitiveness ‘appears to have finally turned a corner’, KMPG said as it summarised the findings of a survey
On 7-9 November 2011, delegates from Working Party No. 6’s Special Session on the Transfer Pricing Aspects of Intangibles (“WP6-TPI”) met with private sector representatives to discuss definitional and ownership
On 30th September 2011 the drafting of a new law was approved by parliament in Guernsey that would protect image rights and see the introduction of registrable image rights in
Spain has signed TIEAs with the following territories:
As a reminder of the Internal Revenue Code (“IRC”) § 6048(a), the 2011–2012 Priority Guidance Plan of the US Tax office focuses again on the reporting requirements for foreign trusts.
Konsilia, the Spanish and Qatari member Firm of The Leading Edge Alliance contributed to the publication of “Transfer Pricing, a comparative Analysis of 60 countries” published by REA, our associated
Let’s be consistent with EU legislation and ask for an immediate removal of Gibraltar from the Spanish list of tax havens (RD 1080/1991). According to Spanish legislation, a jurisdiction will be
Once again the Campus of Jerez was the centre point for a development framework of a special forum which involved tax advisors, students, university professors and personnel from the Tax
How far can the US and the EU governments go to increase taxes and social security charges on wages?. With the purpose of balance their budgets, we believe that higher
The list below contains the Tax Information Exchange Agreements (TIEAs) signed by Gibraltar. Belgium-Gibraltar (16 December 2009) Iceland – Gibraltar (16 December 2009) Sweden – Gibraltar (16 December 2009) Faroes
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