Application of the Spanish GAAR to a Cross-Border Financing Structure Implemented by a Multinational Group through a Netherlands Entity

Journal

Author

Sánchez de Castro Martín-Luengo, E.

Country

Spain

Published Date

April 7, 2022

Issue

European Taxation 2022 (Volume 62), No. 5

DOI

https://doi.org/10.59403/1g88be0

Document

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In this article, the author discusses a case in which the Spanish general anti-avoidance rule was applied to a cross-border financing structure implemented by a US multinational group through the incorporation of a Netherlands financing entity.

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Application of the Spanish GAAR to a Cross-Border Financing Structure Implemented by a Multinational Group through a Netherlands Entity