International Tax Services - Transfer Pricing - Spanish VAT Registration - Zurbano Advisers and Consultants

International Tax

Zurbano Advisers and Consultants

Our team can provide assistance to manage the complexities of multiple tax systems and supranational regulations.

We will help you find comprehensive approaches in typical business events such as: post acquisition integration and restructuring, expansion, investment, divestment, private finance and refinancing, digitization and e-business, etc.

Our services consist, among other, of:

  • BEPS Risk Analysis and Advisory
  • Cross-Border Direct Tax Advisory Services
  • Transfer Pricing
  • Avoid double taxation
  • Mutual Agreement Procedures (“MAP”) & Eliminate double taxation
  • Tax audits

BEPS

Base Erosion and Profit Shifting (BEPS) refers to tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations. Over 100 countries and jurisdictions are collaborating to implement the BEPS measures and tackle BEPS, amongst them Spain.

The global campaign to address tax BEPS is changing the Tax landscape.

The OECD/G20 BEPS Project creates a single set of consensus-based international tax rules to protect tax bases while offering increased certainty and predictability to taxpayers developed in 15 actions:

  • Action 1. Addressing the tax challenges of the digital economy
  • Action 2. Neutralising the effects of hybrid mismatch arrangements
  • Action 3. Designing effective controlled foreign company (cfc) rules
  • Action 4. Limiting base erosion involving interest deductions and other financial payments
  • Action 5. Countering harmful tax practices more effectively, taking into account transparency and substance
  • Action 6. Preventing the granting of treaty benefits inappropriate circumstances
  • Action 7. Preventing the artificial avoidance of permanent establishment status
  • Action 8 – 10. Aligning transfer pricing outcomes with value creation
  • Action 11. Measuring and monitoring BEPS
  • Action 13. Transfer pricing documentation and country-by-country reporting

Tax treaty network

The aim of the treaty network is to eliminate double taxation and provide for reduced rates of withholding tax or dividends, interest and royalties. Spain’s treaties generally follow the OECD model treaty, providing for relief from double taxation on all types of income, limiting the taxation by one country of companies resident in the other and protecting companies resident in one country from discriminatory taxation in the other.

Albania
Germany
Andorra
Saudi Arabia
Algeria
Argentina
Armenia
Australia
Austria
Barbados
Belgium
Bolivia
Bosnia and Herzegovina
Brazil
Bulgaria
Canada
Czech Republic
Chile
China
Cyprus
Colombia
South Korea

Costa Rica
Croatia
Cuba
Denmark
Ecuador
Egypt
United Arab Emirates
Slovakia
Slovenia
The United States
Estonia
Philippines
Finland
France
Georgia
Greece
Netherlands
Hungary
India
Indonesia
Iran
Ireland

Iceland
Israel
Italy
Jamaica
Japan
Kazakhstan
Kuwait
Latonia
Lithuania
Luxemburg
Macedonia
Malaysia
Malta
Morocco
Mexico
Moldova
Nigeria
Norway
New Zealand
Oman
Pakistan
Panama

Poland
Portugal
United Kingdom
Dominican Republic
Romania
Russian Federation
El Salvador
Senegal
Serbia
Singapore
South Africa
Sweden
Switzerland
Thailand
Trinidad and Tobago
Tunisia
Turkey
States of the former Soviet Union (except Russia)
Uruguay
Uzbekistan
Venezuela
Vietnam

Unilateral taxation reliefs

Resident taxpayers are granted a tax credit for foreign direct taxes paid that are similar to the Spanish corporate income tax. The credit is limited to the lesser of the tax payable in Spain if the income had been obtained there, or the actual foreign tax paid.

This double taxation relied also may apply to dividends and capital gains that do not qualify for the participation exemption, or where the taxpayer elects not to apply the participation exemption. In the case of dividends, additional double taxation relief may apply for the underlying foreign corporate income tax liability paid by the participated entity.

If you have any doubts consult our FAQs