Executive summaryOn 13 February 2020, the Spanish Government published a Resolution clarifying the interpretation of the features to be considered for foreign entities to be seen as transparent for Spanish tax purposes.Detailed discussionBackgroundSpain’s Nonresident Income Tax (NRIT) Law sets forth look-through tax treatment for entities whose legal nature is identical or analogous to that of look-through entities incorporated under Spanish law. In principle, this regime applies regardless of the tax treatment applicable in the country in which the entity is incorporated or in which the partners or members of the same reside.However, the Spanish law does not include any further...