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 TEAC confirms that the special tax regime of Law 49/2002 is elective: non-resident foundations must exercise prior election and formal notification before the chargeable event. Retroactive application is not …
The CJEU clarifies that virtual currency confined to the internal use of a video game is not a non-traditional currency for the purposes of article 135(1)(e) of the VAT Directive and is subject to the tax under the …
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 High Court of Justice of Catalonia confirms that losses from other economic activities do not enter the denominator of the 50% management-functions calculation in the family-business exemption. The rejection of the …
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 TEAC confirms that the notification made at the contributor's tax domicile, despite the designation of a representative with a domicile for notifications, is valid if it reaches the effective knowledge of the …
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 …
The DGT confirms that remote work from Spain, through exclusive telematic means, is sufficient to trigger the Beckham regime without a Spanish contract or a Law 14/2013 visa. The risk zone shifts to the foreign employer.
The DGT confirms that the contribution of subsidiaries to a holding does not break the family-business exemption: the prior remuneration from the transferred subsidiaries is not integrated into the 50% calculation at the …
The DGT confirms that a total division aimed at preparing succession and facilitating generational handover is a valid economic reason under article 89.2 of the LIS and accesses the FEAC regime.