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Taxation of non-residents by IP and ITSGF
In accordance with the provisions of the response to binding consultation V1697-23, a resident in the United Kingdom who owns shares or social interests in a non-resident entity in Spain through which he or she participates in entities with properties located in Spanish territory, always and when these constitute, indirectly, at least 50% of the value of the assets of this entity, it will be considered a taxpayer of the Wealth Tax and the Temporary Solidarity Tax of Great Fortunes due to real obligation for the shares of which be direct owner.
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Reform on the Capitalization Reserve
On June 27, 2024, Royal Decree 4/2024 was published, which modifies article 25 of the Corporate Tax Law, establishing the following changes: The increase in the reduction in the tax base on the Capitalization Reserve, of 10 to 15 percent; and, on the other hand, the period contained in art 25.
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TEAC Resolution 00/06452/2022/00/00 of 04/22/2024
The issue raised in the Resolution of the Central Economic-Administrative Court of April 22, 2024 concerns the controversial application of the FEAC regime provided for in Chapter VII of Title VII of the Corporate Tax Law.
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