Shareholder exit through a capital reduction: two routes to channel liquidity and their taxation
A capital reduction can be used to channel liquidity from a company to one or more shareholders without having to distribute a dividend to all…
Category
Tax law
80 articles
Spanish tax authorities reassess retirement pensions and pension plan withdrawals of Spaniards under Portugal’s Non-Habitual Resident regime
The tax audit bodies of the Spanish Tax Agency (AEAT) are reassessing Spanish pensioners who, after moving to Portugal under the Non-Habitual Resident regime (NHR),…
The Spanish Tax Agency reverses a change in position applied de facto: U.S. entities may recover input VAT incurred in Spain by submitting an IRS certificate and a Resale Certificate
Supplementary report of the National Tax Management Office (Oficina Nacional de Gestión Tributaria) of April 28, 2026 (available here). Starting in mid-2025, businesses and professionals…
Setting up a holding company mid-year: how is the main remuneration requirement for the Wealth Tax exemption calculated?
The Directorate General for Taxation (DGT), in its binding ruling (consulta vinculante) V0145-26, of January 27, 2026, addresses an issue of considerable practical significance: when…
Holding company management services to subsidiaries are not a single supply for VAT purposes: implications of the Högkullen judgment for Spanish groups
Judgment of the Court of Justice of the European Union (CJEU) of July 3, 2025 (Case C-808/23, Högkullen AB) The relationship between holding companies and…
The Supreme Court relaxes the employee requirement for rental companies in family groups: a step forward, with caveats
Supreme Court judgments (STS) 637/2026 of February 17 (appeal no. 1196/2024), 640/2026 of February 19 (appeal no. 1326/2024), and 874/2026 of February 20. _____________________________________________ One…
The EU General Court reinforces the right to deduct input VAT even where the invoice is received outside the accrual period
Judgment of the General Court of the European Union of February 11, 2026 (Case T-689/24) The recent judgment of the General Court of the European…
Central Economic-Administrative Court (TEAC)
Statute of limitations and the FEAC regime: how long can the AEAT challenge the contribution of shares to a holding company when there are undistributed profits?
The growing volume of litigation surrounding transactions covered by the special tax-neutrality regime for mergers, divisions, contributions of assets and exchanges of shares (FEAC regime)…
Regularization of FEAC transactions lacking valid economic reasons: the temporal and material scope of the adjustments according to the TEAC
The special tax regime applicable to certain business restructuring transactions (the special tax-neutrality regime for mergers, divisions, contributions of assets and exchanges of shares, or…
The DGT turns Bitcoin into a tax problem: paying with cryptocurrencies will be costly and cumbersome
The Directorate General for Taxation (DGT) has issued binding ruling (consulta vinculante) V0935-25, according to which payments in Bitcoin constitute an exchange (permuta) of intangible…