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

Journal
Sánchez de Castro Martín-Luengo, E.
Spain
European Taxation 2022 (Volume 62), No. 5
PriceUSD 45

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.