International taxation
International taxation applicable in Spain: double tax treaties, EU freedoms, exchange of information, Spanish CFC rules, Pillar 2 (GloBE) and DAC6. 5 analyses and 1 note, most recent first.
- DGTV5374-26Beckham
Carried interest and the Spanish impatriate regime: the DGT confirms that carried interest deriving from points allocated before the move is not taxed in Spain (V5374-26)
- DGTV1648-26Residence
Exit tax and relocation to Switzerland: the DGT confirms deferral, clarifies the effect of a gift to the spouse and rules out Wealth Tax under limited tax liability (V1648-26)
- TJUEC-203/25Non-residents
Parent-Subsidiary Directive and chains of transactions: the CJEU judgment in Neo Group allows the withholding tax exemption to be denied even where the parent company carries on a genuine activity
- ANSAN 167/2026Residence
Tax residence by physical presence: the Spanish National High Court sets aside the assessment of a well-known singer because the Administration fails to prove 183 days
- TSSTS 7/2026Non-residents
VELCRO case: with the Directive exemption refused for lack of beneficial ownership, the Spanish Supreme Court denies the treaty rate on the basis of EU-law primacy
- Note
VELCRO: no beneficial owner, neither the Directive exemption nor the reduced treaty rate