You feared as much… Corporate tax

You feared as much… Corporate tax

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Calm down, call our lawyers. We are specialist in international taxation and tax optimisation. Let us advise you on a suitable tax planification

In Evolutiza Lawyers & Tax Advisors, we have extensive experience in taxation and transfer pricing. Do not hesitate to contact us.

We are a Spanish law firm with branches Chile, Peru, El Salvador, United Kingdom and Switzerland devoted to business.

We are specialist in corporate law, international taxation, contracts, taxes, IP, transfer pricing and finance.

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Be strange but don´t be a stranger

Let us tell you about the main innovations introduced by Law 27/2014, of corporate tax in Spain:

1. Enforced the civil companies to the Corporate Tax form hitherto taxed for income tax on imputed income regime.

2. In cases of operations or deferred payment terms, the income shall be understood as obtained in proportion to the corresponding charges are payable. Thus solving the problems that existed before in case of defaults.

3. Tax base:
- Temporary imputation: update accrual following the PGC and PGC for SMEs.
- Amortization: art. 12.2 eliminate the maximum annual limit for the deductibility of the amortization charge for intangible assets with finite useful life and the requirements to be met. Paragraph 3 of that article introduces the freedom of depreciation for property, plant and new material.
- Linked transactions: art. 18.2, last paragraph introduces a novel way to restricting the scope of relationship in the field of partner-society relationship, which is set at 25 per cent of participation.
- Compensation in tax base negative: no time limit, but quantitative: 70%.
4. Treatment of double taxation: exemption regime is established for dividends received and gains on the transfer of shares, whether the shares of Spanish as foreign entities. But there are some exceptions. The exemption does not apply to dividends or profit sharing distribution which generates a tax-deductible expense for the payer.

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