English LPA in Spain: Recognition and Law 8/2021
Recognition, Jurisdiction, and the 2021 Law Reform For many British expatriates and high-net-worth individuals, managing an English LPA in Spain is a cornerstone of future planning. These documents, prepared under the Mental Capacity Act 2005 and registered with the Office of the Public Guardian, are designed to ensure that trusted people can make decisions on a donor’s […]
Navigating International Taxation: The Realities of the UK-Spain Treaty
International taxation often feels complex. Its main instrument, the double taxation treaty, is frequently misunderstood. Many professional errors arise not from technical difficulty, but from a failure to understand what a treaty does, what it covers, and where its limits lie. This article focuses on the interaction between the UK and Spain, including UK residence […]
Substance Over Structure. Redefining the Boundary Between Tax Abuse and Simulation in Spain
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 long troubled cross-border tax planning. The decision addresses the relationship between simulation of transactions under Article 16 of the Spanish Tax Law (Ley General Tributaria […]
Beckham Law Meets the UK LLP: Spain’s Tax Office Issues Game-Changer for Expatriates
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, such as changing residence status, but through technical missteps in the architecture of income. One such risk has worried inbound taxpayers for years: what happens […]
Counting Days, Creating Risk: Why the UK and Spain Still Get Tax Residence So Differently
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 internationally mobile professionals, tax residence is rarely a question of where one lives in the ordinary sense. It is a question of how days are […]
The Ultimate Guide to UK Tax Residency: The Statutory Residence Test (SRT) Explained
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 Residence Test (SRT) will dictate your tax obligations. This rigid, objective framework replaced the previous subjective tests in 2013, providing much-needed clarity for globally mobile […]
Beckham Law Withholding Tax Vacuum: Do US or UK Employers Need to Run Spanish Payroll?
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 it, the regime allows qualifying individuals to pay a flat 24% tax rate on their worldwide income, while other foreign-sourced investment income and gains are […]
Changing your Tax Residency: Key steps to avoid costly mistakes
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 behind the headlines lay a far more complex challenge: navigating the labyrinth of international tax residency rules that could make or break their financial futures. […]
The Spanish Beckham Tax Rule Vs Permanent Establishment Risk: Which Matters More for Your Spanish Move?
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 plans: Will your work arrangement create a Permanent Establishment (PE) that disqualifies you from the tax benefits you’re seeking? The 2025 Update to Article 5 […]
Invalid Notifications in Spain and HMRC Recovery in the UK: A Procedural Defence for Cross-Border Taxpayers
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 cases, the underlying issue is not the amount of tax assessed but a procedural flaw: the taxpayer was never properly notified in Spain. What may seem a […]
Huge Win for Non-Residents: Spain’s Supreme Court Opens Wealth Tax Refunds for Non Residents
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 time, the Court has confirmed that non-residents are entitled to the Wealth Tax protection cap (límite conjunto de tributación), a mechanism that prevents the combined […]
Spanish Non-Resident Tax on Employment Income: When Does It Apply?
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 Income Tax (IRNR) can apply even when you’re not a Spanish tax resident, and understanding when this obligation arises is crucial for avoiding penalties and […]
Trusts in Spain: An Incoherent Legal and Tax Approach
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 or more beneficiaries. The trustee holds legal title, while the beneficiaries enjoy the equitable or beneficial interest. Although often compared to civil law concepts such […]
Why Private Wealth is the Next Tax Frontier – Published in Taxation
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. The piece looks at how governments are gradually shifting their attention away from corporate taxation and towards the taxation of private wealth – a change […]
New ETA and Rising Fees: Your Guide to UK Travel and Immigration Changes
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, can feel like navigating a labyrinth using a poorly designed map. In this instance, the United Kingdom’s system is no exception and, in fact, because […]
Challenging Spanish Tax Office’s notification system to UK residents
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 nº 2 de la Audiencia Nacional). In 2019, a Spanish tax resident client faced a tax inspection regarding their 2015 Income Tax Return. The Spanish […]
Solidarity Tax on large fortunes: Key points for 2024
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 unconstitutionality. The Constitutional Court, however, swiftly upheld its legality. Consequently, taxpayers must once again self-assess and, if applicable, pay this tax. What does the ITSGF […]
Can I apply for Beckham Rule if I am a director of a Spanish Company?
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 years even if you are a shareholder of that company. If the company is a “passive assets-owning company,” the director’s stake in the company cannot […]
Do I require a TIE card if I hold a Golden Visa or Digital Nomad Visa issued by a Spanish Consulate?
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 of applications at the Spanish Consulate and from within Spain concerning the issuance of TIE cards. Option 1: Application at the Consulate Investors and Digital […]
International Tax Conference
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 international tax event in Milan (Italy) to discuss “Recent Trends on Permanent Establishment, Business Nexus and Profit Allocation”. With respect to the organisation of the […]
Is it possible to buy or sell Spanish property from the UK and in pounds?
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 and euros. But as we explain in this article, it’s perfectly possible to carry out the transaction in the UK, in pounds and using a […]
Let your lawyer handle your financial and property affairs
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 documents on behalf of their clients so that they do not have the expense and the inconvenience of having to attend in person to sign […]
Brits living in Spain go up by 9.5% in 2 years, but should you become tax resident in Spain?
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% shy of its record in 2013. Despite the challenges of Brexit, the number of British becoming residents in Spain has increased by 9.5% since 2019. […]
Income Tax arrangements for internationally mobile employees
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 employees. While many countries have a double taxation agreement (DTA) in place with the UK, meaning a tax refund can be claimed where tax has […]
Inheritance Tax and estate planning for overseas buyers of UK residential property
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, consideration needs to be given as to how the property will be owned to ensure it is as tax efficient as possible in respect of […]
Using a family investment company to pass on wealth
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 some distinct advantages. Traditionally in anglo saxon jurisdictions, trusts have often been used to protect wealth and shelter assets from Inheritance Tax liability. However, over […]
Global minimum corporate tax and impact on tax treaty shopping
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 and online tech companies from avoiding tax in many of the countries in which they operate by seeking out favourable tax havens elsewhere. The deal […]
Do Brits who overstay in EU post-Brexit face deportation?
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 the 90-day limit outside of the UK post-Brexit, but Spain has dismissed reports that those breaking the law will be immediately deported. Although the latest […]
Setting up a business in the UK
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 relatively cheap and easy and the UK’s tax structure means in the early, less-productive years a business will not be heavily taxed. It is important […]
Taxation of british pensioners in Spain
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 for any British citizen interested in relocating to Spain. Besides the obvious attractions, such as a nicer climate and beautiful environments, the relatively lower costs […]
Spanish and EU residents in the UK after Brexit (Part II)
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 and criteria employed to access settled and pre-settled status. Now, we will take a look at the relevant tax implications of the proposed transition of […]
A Global Analysis of Tax Treaty Disputes
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 LSE, reviewed with his collaborators around 1,500 cases, where Eduardo finally included in his book a ‘Global Taxonomy’ of 116 tax identified patterns of tax […]
Gibraltar and its tax regime: more complexity in the negotiations of the Brexit
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 Brexit negotiations or posteriori on a bilateral basis. Gibraltar is the most controversial territorial issue of Brexit. It is not yet known what will become […]
Gibraltar calls for more support against interference from Spain and the EU
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 London in supporting the Rock in the negotiations of Brexit. Gibraltar’s chief minister, Fabian Picardo, has called on UK Prime Minister Theresa May to make […]
The Home Office changes the EEA (PR) Guidance Notes
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 these citizens to subscribe to an email alert instead of applying to a PR due to the huge increase of applications since the Brexit date. […]
ISA Accounts: Effortlessly Save (tax) in the UK
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 that will make them more attractive. Helping families to increase their savings levels: that was the idea of the North American economist Chris Edwards to […]
EU countries agree on taking a step forward on anti-avoidance rules
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 implement the whole OECD recommendations for BEPS. International tax avoidance has been the new taxation battlefield for OECD and the EU’s tax authorities since 2015. […]
Del Canto Chambers: Universal jurisdiction and self-regulation to tackle tax fraud
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 Review magazine in which he bets for applying universal jurisdiction principles and CDPs for tax professionals in order to effectively fight against international tax fraud. […]
Del Canto Chambers: fight against tax avoidance is key to restore confidence in tax system
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 BNA on the Joint International Taskforce on Shared Intelligence and Collaboration’s meeting (JITSIC) that took place in Paris Del Canto considers that “narrowing the space […]
The British government eases the inheritance tax regime
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. In the UK young people will inherit more but in more unequal conditions in the future. This is clear from a report presented by the […]
Del Canto Chambers bets for Spain as British housing investments' destination
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 highlights that Spain, despite Brexit and the Sterling’s devaluation, is still an important destination for British wanting to purchase a property in our country. For […]
Life after the Panama Papers
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The EC keeps fining Apple for breaching state aid regulations
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 without any basis and for breaching the state aid rules. The European Commission has recently published its report on the conducted investigation to the giant […]
SPEAR’S – International Tax Avoidance
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 in the global tax avoidance’s fight.
Del Canto Chambers advocates for the tax advisors' leadership on the fight against fraud
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 on the consensus necessity among professional international tax advisors and States in the global tax avoidance’s fight. For Del Canto, the starting point is the […]
Gibraltar: the Brexit's territorial problem
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 Picardo, advocated in the British TV Channel “BBC” that the upcoming negotiations between London and Brussels to negotiate Britain’s exit from the EU should consider […]
Football Leaks: The tax evasión league
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 newspaper “Der Spiegel” known as Football Leaks, has revealed that several European clubs and soccer players have committed a crime of tax evasion. This newspaper […]
Del Canto Chambers also bets for the "universal jurisdiction" for tax frauds
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 he defends the application of the universal jurisdiction principle for tax crimes to make the fight against international tax avoidance more effective.
Del Canto Chambers bets for HMRC to get powers of action against fraud in Overseas Territories too
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 of action against tax fraud in Overseas Territories too. Del Canto highlights that it is, especially, “at an international level, which is where the majority […]
Del Canto Chambers: Gibraltar is the yardstick to measure Spanish-UK’s relations
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 the Gibraltar’s current status after Brexit and the Spanish’s co-sovereignty purposes with the United Kingdom.
The Barrister Magazine – Gibraltar the yardstick of the future of Spanish and British relations
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 Barrister Magazine, where he analyses the Gibraltar’s current status after Brexit and the Spanish’s co-sovereignty purposes with the United Kingdom.
HNWI: The British tax authorities’ goal
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 public deficit reached up to 4.20 of GDP. To cover that hole is a priority for the State to regain income. This goal was entrusted […]
Bloomberg BNA – UK should Extend Tax Offenses Bill to its Territories
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 to get wider powers of action against tax fraud in Overseas Territories too.
The European Commission proposes a corporate tax’s common tax base
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 harmonize the corporate tax’s base between the 28 States members. This Consolidated Common Corporate Tax Base (CCCTB) would allow businesses to pay taxes where they […]
Del Canto Chambers defends more fiscal transparency in the United Kingdom
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 asked for more tax transparency in its Overseas Territories and Crown Dependencies such as the British Virgin Islands or Gibraltar”. “They’re asking the U.K. to […]
Brexit could help to simplify the British tax system
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 an improvement, according to the Institute of Directors, which defines it as “punishingly complex”, a system that hinders the United Kingdom’s growth and harms taxpayers’ […]
‘Non-doms’ in the UK to reshape their taxation schemes
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 radically change since April 2017 and it will do more once London calls upon Article 50 of TEU to start the EU’s exit negotiation with […]
The United Kingdom, tax-cleaning Overseas Territories
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 Revenues & Customs) received information on hundreds of thousands of offshore bank accounts of American citizens and residents from the United States, in compliance with […]
Del Canto Chambers thinks that the HMRC's antifraud measures are 'excessive'
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 VAT fraud. The article, written by the journalist Ben Stupples, is titled “UK proposes new penalties for VAT fraud” and it gives details on the […]
Bloomberg BNA – last measures that HMRC has implemented to fight against VAT fraud
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 implemented to fight against VAT fraud.
When the taxpayer becomes a client
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 fiscal sector. Last February, the Spanish Association of Tax Advisors (AEDAF) criticized the plan of incentives against tax fraud that the Spanish Tax Agency negotiated […]
McDonald's: new target in the EU tax offense
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 McDonald’s could face a fine imposed by the European Union of 466 million Euros in back taxes to be paid to Luxembourg. We are witnessing […]
Del Canto Chambers explains Apple Inc's case at Bloomberg in Spain
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 the European Commission to pay 13bn euros in back taxes to Ireland. Journalists Rick Mitchell and Ben Stupples wrote in their article “Apple may face […]
Between universal jurisdiction and international taxation, it has been a busy week at Del Canto Chambers
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 have kept us busy this week at Del Canto Chambers At Del Canto Chambers, as we approach the end of the summer and brush away […]
A very busy week at Del Canto Chambers
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 case. Meanwhile, the firm continues to strengthen its position as the first Spanish office in Qatar. Along with Leon Fernando del Canto, our Managing Partner, […]
León Fernando del Canto on The Times: Direct tax is a sovereign responsibility of individual EU states
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 León Fernando del Canto on the current €13bn’s fine that the European Commission has ordered Apple to pay to Ireland in back taxes. On the […]
The Times – Apple, state aid and "illegal" tax breaks
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 que la Comisión Europea ha impuesto a Apple para pagar a Irlanda en concepto de impuestos atrasados.
León Fernando del Canto focus on the UK's role in tax avoidance
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 and the UK’s role in it. International tax avoidance is a burning issue both media both public opinion. Cases such as WikiLeaks or the most […]
Investment profitability and business opportunities between Europe and the Middle East
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 week at Del Canto Chambers, we have had one foot in Europe and the other in the Middle East; tax issues and business matters have […]
International Taxation: No peace for evaders
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 led the way this week at Del Canto Chambers. We have analysed the emerging sector of Islamic finance, the BEPS (Base Erosion and Profit Shifting) […]
Gibraltar: a nearby destination for international Family Office
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 regulatory and banking framework withstand the tests of the OECD and the European Bank and regarding Brexit, having signed a number of treaties to exchange […]
Brits who commit fraud risk large fines for tax evasion
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 seeks to impose sanctions of up to 100% of the taxes evaded. The plan is a continuation of the anti-fraud measures developed by the former […]
Del Canto Chambers discusses international tax evasion
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 Chambers we have focused on providing analysis on international tax evasion. Since 2013, the OECD, has leads the Base Erosion and Profit Shifting (BEPS) Project. […]
BEPS: Welcome to the OECD 2.0
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 (Base Erosion and Profit Shifting) is combating international tax fraud with a true multilateral tax reform proposal in a paper called “Action Plan on Base […]
BEPS project: global consensus against tax evasion
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 “world market”. Doing business globally also involves generating wealth on a global level, which, eventually, must be taxed. Countries, through multilateral or bilateral agreements, negotiate […]
Seven tips that you should know about the new tax amnesty prepared by Turkey
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 in the international automatic exchange tax information field. In this regard, the Turkish government submitted to its parliament a draft law to enhance the investment […]
Short-term double or quits on M&A and taxation
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 European banks crisis (with Italy and Portugal just about to be rescued), the emerging economies’ lower growth and international markets’ instability are affecting the financial […]
Nothing will change after the Panama Papers
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 that allows hiding funds offshore avoiding the tax authorities”. Does that mean international tax evasion is dead? As the most seasoned readers will be guessing, […]
Fair Tax Mark to reward tax justice
¨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 transparency and fairness in corporate taxation practices and policies.¨ “In this world nothing can be said to be certain, except death and taxes.” For many, […]
Jersey Threatens to Break with UK over Tax Backlash
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 can be found at The Guardian here, or can be read below: A barrage of regulatory clampdowns and political attacks on the Channel Islands’ controversial […]
Balancing the Books
£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 the challenging economic conditions, football clubs are continuing to increase revenues and with £1.2bn paid to the treasury in Tax, football’s worth to the overall […]
OECD launches Tax Inspectors Without Borders
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 new initiative to help developing countries bolster their domestic revenues by making their tax systems fairer and more effective. Building on that concept, the OECD […]
Football Financial Future
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 on the UEFA model, Championship clubs will have until the 2014/15 season to get their house in order or face stiff penalties. Leagues One and […]
The average tax burden on earnings in OECD countries continues to rise
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 incomes increased in 26 out of 34 OECD countries in 2011 according to the new OECD Taxing Wages publication. Tax payers in Ireland, Luxembourg, Portugal and the […]
UK Tax Budget 2012
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 George Osborne’s third Budget were so well rehearsed that the real thing threatened to be an anti-climax. Was there anything left that the Chancellor could […]
US Non Resident Green Card Holders Must Revisit Their Position
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 to properly report and pay taxes on assets held abroad. These amnesty programs require U.S. taxpayers to pay any overdue tax, penalties and interest on […]
Tax: OECD to Simplify Transfer Pricing Rules
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 simplify transfer pricing rules, strengthen the guidelines on intangible issues and improve the efficiency of dispute resolution. Transfer pricing rules determine how international transactions within […]
OECD Recommends Action on International Tax Loopholes
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 Policy and Compliance Issues describes arrangements that exploit national differences in the tax treatment of instruments, entities or transfers to deduct the same expense in […]
Spain Supreme Court decision: Swiss principal has Spanish PE through its subsidiary in Spain
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
KPMG Survey Suggests Progress on UK Tax Competitiveness
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 of 50 large businesses operating in the UK. In 2009 only 17% of respondents said the UK had ‘the most competitive tax system compared to […]
OECD Meets with Business Commentators on the Valuation of Intangibles for Transfer Pricing Purposes
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 issues related to transfer pricing for intangibles. The agenda for the meeting, presentation material submitted by private sector participants and list of participants have now […]
Guernsey Takes a World Lead with New Image Rights Legislation
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 time for London’s Olympic Games and the 2012-2013 football transfer season. Jason Romer, Managing Partner at Collas Crill, reported that if enacted the proposed legislation […]
Spanish list of Tax Information Exchange Agreements
Spain has signed TIEAs with the following territories:
US Citizens and Offshore Trust Reporting Obligations
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. The IRC Code § 6048(a) imposes a duty upon the “responsible party” (settlor or transferror) to provide written notice of any “reportable event” to the […]
INTERNATIONAL TRANSFER PRICING REVIEW
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 Firm in Peru. The report compares the regulatory treatment of transfer pricing in 60 countries and how they affect the allocation of gains in intra-group […]
Gibraltar should not wait for the exchange of information treaty with Spain
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 removed from this list if there is a treaty signed including a clause for the exchange of tax information.
Questions regarding the prevalent Tax Law of the European Union
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 Office. On this occasion, a new conference took place on questions of the prevalent taxation within the European Union which the University of Cadiz imparts […]
Increased Income Tax rates.- is it any good for the real Economy?
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 taxes on employment are suffocating the real economy and the prospects for employment generation.
Gibraltar update on Tax Information Exchange Agreements TIEAs
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 Islands – Gibraltar (20 October 2009) Finland – Gibraltar (20 October 2009) Greenland – Gibraltar (20 October 2009) Portugal – Gibraltar (14 October 2009) France […]
