Executive summary
Spain published rules amending the existing Spanish controlled foreign companies (CFC) regime in July 2021 (For background, see EY Global Tax Alert, Spain approves Anti-Tax Fraud Law, dated 16 July 2021); among other changes introduced, the scope of application of CFC provisions were broadened to include dividend income and capital gains derived by intermediate non-Spanish holding companies which qualify as CFCs.
In addition, the Spanish State Budget Bill introduced a limitation …