The Spanish Supreme Court confirms that the judicial authorisation of home entry under article 113 of the LGT must specifically motivate access to digital repositories —emails, servers, cloud— that affect other rights of …
The Spanish Supreme Court applies the general TRLIRNR withholding where the receiving company channels the royalties to a third party: neither the Directive 2003/49/EC exemption nor the reduced bilateral-treaty rate.
The Spanish Supreme Court confirms the restrictive interpretation of article 93.1.a) of the LIRPF: the contributor must have been a non-resident for tax purposes —not merely physically absent— during the five tax periods …
The Criminal Chamber of the Spanish Supreme Court confirms that the foreign tax-residence certificate is relevant evidence but does not exhaust the evidential question in criminal proceedings: it yields where there is …
The Spanish Supreme Court confirms that the court may directly annul the penalty of article 171.One.4 of the VAT Act for disproportionality in reverse charge cases, without need to refer the matter to the Constitutional …
The Spanish Supreme Court confirms that intragroup transfers of participations by a mixed holding company are part of the financial differentiated sector for VAT purposes, save where they entail the transfer of an …
The Spanish Supreme Court confirms that a tax self-assessment is not an administrative act. The ordinary review channel where it is considered contrary to law is the rectification of article 120.3 of the LGT, exercised …