Tax Ruling Offers Welcome Clarification on Spanish Regime for Qualifying Bond Offerings


New tax ruling addresses controversial aspects of the Spanish tax regime applicable to qualifying bond offerings.

The Spanish Tax Authorities recently published Binding Tax Ruling V3670-13 (the Ruling), which addressed certain controversial features of the special Spanish tax regime applicable to certain qualifying bond offerings — which is governed by Additional Provision Two of Law 13/1985. The Ruling suggests the Spanish Tax Authorities are taking a market-friendly approach, though additional reforms likely are still required.

Background -

The Spanish special tax regime, inter alia, does not apply Spanish withholding tax on interest payments made to non-Spanish resident investors, as well as, among others, listed Spanish companies that issue bonds directly or through a special purpose vehicle (SPV) located in Spain or in another European Union Member State1 (other than a tax haven for Spanish tax purposes).

Please see full Commentary below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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