Tag: Exemption

Spain releases report on application of their General Anti-Abuse Rule.

The Spanish tax authorities have published a report on the applicability of their domestic General Anti-Abuse Rule (GAAR). In the report, a conduit arrangement aimed at benefiting from an exemption at source on the payment of interest to EU residents is described. Click here for English translation Spain GAAR report ...
Beneficial owner, Conduit arrangement, Empty shell, EU interest and royalty directive, Exemption, General Anti-Avoidance Rule (GAAR), Interest, Intra-group loan, Lack of substance, Loan, Netherlands, Supplemental guidance