Spain’s amendments to CFC rules and participation regime may require action by multi-tier international structures under Spanish holdings
Executive summary
Spain published rules amending the existing Spanish controlled foreign companies (CFC) regime in July 2021 (For background, see EY Global Tax Alert, Spain approves Anti-Tax Fraud Law, dated 16 July 2021); among other changes introduced, the scope of application of CFC provisions were broadened to include dividend income and capital gains derived by intermediate non-Spanish holding…
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