Executive summary
On 13 February 2020, the Spanish Government published a Resolution clarifying the interpretation of the features to be considered for foreign entities to be seen as transparent for Spanish tax purposes.
Detailed discussion
Background
Spain’s Nonresident Income Tax (NRIT) Law sets forth look-through tax treatment for entities whose legal nature is identical or analogous to that of look-through entities incorporated under Spanish law. In principle, this regime applies regardless of t…