The interpretation of the anti-abuse clause in the neutrality regime has been a source of great controversy in the past, at the same time that the administrative criteria for their application were developing and the jurisprudence gave answers about its most controversial aspects. It has required a special effort from everyone the interpretation of the expression «tax evasion or tax avoidance». Also the fixation of the role of «absence of valid economic reasons» to appreciate its existence as a cause of exclusion of the regime. However, it is relatively recent the intervention of the Supreme Court answer to the key aspects of the issue. This study aims to show what they are and how they have been tempered the guidelines for the application ...
The conflicts between the tax Administration and the tax debtors in relation to the origin of the en...
Este trabajo ha obtenido el Primer Premio Estudios Financieros 2010 en la modalidad de Tributación.L...
In the reply given by the Court of Justice of the European Union, in its order of October 6th, 2010,...
This paper examines, primarily from the perspective of Spanish law, the application of anti-abuse pr...
The Directive on the tax regime applicable to cross-border interest and royalty payments between ass...
The terms evasion avoidance from the doctrine problems have arisen regarding the scope of its meanin...
The consequences of European Union Law on the interpretation of anti-abuse rules cannot be ignored, ...
A lo largo de este trabajo hemos querido hacer un pequeño resumen del procedimiento hipotecario expl...
This paper examines the main implications arising from the decision of the ECJ (Fifth Chamber) of 10...
To analyze the tax neutrality of the tax system we should first determine if a levy does not alter t...
The Constitutional Court, through several judgments issued in 2017, has declared the unconstitutiona...
The new anti-tax avoidance directive, far from bringing new elements in order to configure the GAAR ...
This paper analyses the possibility that the application of the general anti-abuse rule also entails...
[spa] Las normas generales antielusión son uno de los mecanismos que permiten al Estado luchar cont...
For some time now, it has been observed, in the decisions of the economic-administrative courts, a r...
The conflicts between the tax Administration and the tax debtors in relation to the origin of the en...
Este trabajo ha obtenido el Primer Premio Estudios Financieros 2010 en la modalidad de Tributación.L...
In the reply given by the Court of Justice of the European Union, in its order of October 6th, 2010,...
This paper examines, primarily from the perspective of Spanish law, the application of anti-abuse pr...
The Directive on the tax regime applicable to cross-border interest and royalty payments between ass...
The terms evasion avoidance from the doctrine problems have arisen regarding the scope of its meanin...
The consequences of European Union Law on the interpretation of anti-abuse rules cannot be ignored, ...
A lo largo de este trabajo hemos querido hacer un pequeño resumen del procedimiento hipotecario expl...
This paper examines the main implications arising from the decision of the ECJ (Fifth Chamber) of 10...
To analyze the tax neutrality of the tax system we should first determine if a levy does not alter t...
The Constitutional Court, through several judgments issued in 2017, has declared the unconstitutiona...
The new anti-tax avoidance directive, far from bringing new elements in order to configure the GAAR ...
This paper analyses the possibility that the application of the general anti-abuse rule also entails...
[spa] Las normas generales antielusión son uno de los mecanismos que permiten al Estado luchar cont...
For some time now, it has been observed, in the decisions of the economic-administrative courts, a r...
The conflicts between the tax Administration and the tax debtors in relation to the origin of the en...
Este trabajo ha obtenido el Primer Premio Estudios Financieros 2010 en la modalidad de Tributación.L...
In the reply given by the Court of Justice of the European Union, in its order of October 6th, 2010,...