The internationalization of economic activity worldwide is becoming increasingly important, and many multinational groups are present in Spain, as well as Spanish multinational groups present in other countries.
International tax issues are one of the main areas of the tax control plans that the Tax Agency implements year after year.
Relevant tax issues include international related-party transactions, corporate restructuring transactions, the transfer of intangible assets, the erosion of negative tax bases, and payments for royalties on the transfer of intangible assets or for intragroup services.
The provisions of the BEPS project relating to anti-tax avoidance measures that regulate hybrid mismatches, international tax transparency, the deductibility of financial expenses, and the abuse of double taxation treaties.
The correct application of the Multilateral Convention and the rules on the Complementary Tax are also very important aspects to ensure a minimum overall level of taxation for large multinational and national groups.
To address all these and many other issues that arise in the field of international taxation, we have an extensive network of ETL Group offices in virtually all of our neighboring countries, primarily in Europe, North America, and South America. This network of offices allows us to meet the needs of our clients who have subsidiaries in these countries or who require international expansion.
Our team of professionals has proven experience in identifying tax optimization opportunities, minimizing risks, and avoiding international double taxation situations.
Joan Manuel Mercadé
Tax Advisor
