Spanish Tax Authorities deny withholding tax exemption on interest payments to EU residents based on GAAR
Executive summary
In the context of a tax audit procedure initiated following a spontaneous exchange of information by the Dutch tax authorities, the Spanish tax authorities (STA) challenged the domestic withholding tax exemption on interest paid to European Union (EU) residents based on the application of the General Anti-Abuse Rule (GAAR), on the grounds that the recipient of the interest was a c…
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