The Judgment Of The Court (Grand Chamber) 26 February 2019 can contribute useful tools to the Tax Administrations of the Member States when interpreting and applying European Union law in respect of exemption of interest and royalty payments which are satisfied by one entity to another one according to the Directive 2003/49. The key point is to determine if a company is a beneficial owner of the interests. This Judgment provides arrangements in which there is abuse of rights against the cases where the beneficial owner condition simply does not exist. It highlights certain situations in which the free movement of capital has been violated.La STJUE de 26 de febrero de 2019 puede aportar herramientas útiles a las Administraciones tributarias ...
The Sentence of the Court of Justice of the European Union of July 16, 2020 comes to answer the fift...
This Judgment refers to whether a jurisdiction clause in a contract between two companies can be rel...
Royal Decree-Law 13/2010, of December 3, of performances in the field of taxation, labor and liberal...
The Directive on the tax regime applicable to cross-border interest and royalty payments between ass...
This work carries out the delimitation of the exemption in the European V.A.T., of the benefits made...
El presente artículo lleva a cabo un análisis de las sentencias del TJUE en las que se cuestiona el ...
The information obligation for certain assets and rights abroad, from which the 720 form results, is...
La necesidad urgente de adaptar el marco regulador del sector de la estiba portuaria a las exigencia...
The Court of Justice of the European Union, June 9 and July 28, 2011, confirmed the account as State...
La STJUE de 14 de marzo de 2013 se ha pronunciado sobre el posible carácter abusivo de determinadas ...
This paper analyses the essential aspects of the European regime on unfair terms, marked by the abun...
This article analyzes the possibility of the tax regulation of the reorganization companies to prote...
[Abstract] The capital protection of the employer - the owner and the limitation of liability of ow...
In the reply given by the Court of Justice of the European Union, in its order of October 6th, 2010,...
Financial legislations of each Member State must meet the require- ments of European financial laws....
The Sentence of the Court of Justice of the European Union of July 16, 2020 comes to answer the fift...
This Judgment refers to whether a jurisdiction clause in a contract between two companies can be rel...
Royal Decree-Law 13/2010, of December 3, of performances in the field of taxation, labor and liberal...
The Directive on the tax regime applicable to cross-border interest and royalty payments between ass...
This work carries out the delimitation of the exemption in the European V.A.T., of the benefits made...
El presente artículo lleva a cabo un análisis de las sentencias del TJUE en las que se cuestiona el ...
The information obligation for certain assets and rights abroad, from which the 720 form results, is...
La necesidad urgente de adaptar el marco regulador del sector de la estiba portuaria a las exigencia...
The Court of Justice of the European Union, June 9 and July 28, 2011, confirmed the account as State...
La STJUE de 14 de marzo de 2013 se ha pronunciado sobre el posible carácter abusivo de determinadas ...
This paper analyses the essential aspects of the European regime on unfair terms, marked by the abun...
This article analyzes the possibility of the tax regulation of the reorganization companies to prote...
[Abstract] The capital protection of the employer - the owner and the limitation of liability of ow...
In the reply given by the Court of Justice of the European Union, in its order of October 6th, 2010,...
Financial legislations of each Member State must meet the require- ments of European financial laws....
The Sentence of the Court of Justice of the European Union of July 16, 2020 comes to answer the fift...
This Judgment refers to whether a jurisdiction clause in a contract between two companies can be rel...
Royal Decree-Law 13/2010, of December 3, of performances in the field of taxation, labor and liberal...