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

more+
less-

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.

LOADING PDF: If there are any problems, click here to download the file.


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.

© Latham & Watkins LLP | Attorney Advertising

Written by:

more+
less-

Latham & Watkins LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×
Loading...
×
×