Skip to content
EYEY

Spanish tax authorities deny interest deductions on debt to fund a share premium distribution, overall transaction declared as abusive in binding report

|Tax Alerts, Legislation & Policy, National/Federal Taxation|Netherlands, Spain
Netherlands, Spain
  • The Spanish tax authorities challenged, in a binding report, the tax deductibility of financial expenses derived from debt used to fund a share premium distribution.

  • The challenge was based on the application of the General Anti-Abuse Rule (GAAR), on the grounds that by using several “intermediary” entities and carrying out a series of consecutive intra-group transactions, the taxpayer achieved an anticipated distribution of future profits and generated financial expenses which reduced the tax bu…

Continue reading with a Pro Subscription

Unlock full Orbitax Tax News content, including a historical database of tax news, alerts, and analysis from our network of tax experts, all tailored to your company footprint. Now includes Orbitax XatBot AI Tax Assistant.

Free trial available. Cancel anytime. Free Orbitax account required.

Already a Pro or Pro+ subscriber? Sign in to Orbitax to continue reading.