Look-Through Tax Treatment of Foreign Entities in Spain – Background and New Guidance
Journal
International; OECD; Spain
Bulletin for International Taxation 2020 (Volume 74), No. 6
A new resolution has been issued on the qualification of foreign entities as look-through entities for Spanish tax purposes. It establishes the tax treatment in the jurisdiction of incorporation as the single element to be considered, instead of assessing its legal nature. The resolution, however, increases the level of uncertainty.