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   August 2016  
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Bulletin for International Taxation
This free e-mail service informs you about the contents of the forthcoming edition of Bulletin for International Taxation.

Issue No. 8 - 2016 of the Bulletin for International Taxation is now available online.

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Number 8 - 2016 contains the following:

President's Welcome

Porus F. Kaka

Dear Ladies and Gentlemen, Senoras y Senores, dear IFA Colleagues, bienvenidos to the 70th Congress of the International Fiscal Association (IFA) that is to take place in Madrid from 25-30 September 2016.


The Spanish Transfer Pricing Regime and the OECD/G20 Base Erosion and Profit Shifting Project

Jose Manuel Calderón

This article provides an overview of the Spanish transfer pricing regime with an especial focus on the effects and implications for this regime of the OECD/G20 Base Erosion and Profit Shifting Project.


Spain’s Holding Company Regime

Carlos Diéguez and Luis Alaix

This article describes the Spanish “entidad de tenencia de valores extranjeros” (holding company, ETVE) regime and considers the advantages and disadvantages of the ETVE regime for taxpayers.


Financing Activities: Hybrid Mismatches and the Tax Deductibility of Interest in Spain

Silvia López Ribas

This article discusses the provisions of the Spanish Ley del Impuesto sobre Sociedades (Corporate Income Tax Law) regarding the tax deductibility of interest and the neutralization of the tax effects of hybrid instruments. In doing so, both domestic rules and the recommendations of the OECD and European Union are considered.


The Spanish Position on the Concept of a Permanent Establishment: Anticipating BEPS, beyond BEPS or Simply a Wrong Interpretation of Article 5 of the OECD Model?

Adolfo J. Martín Jiménez

In this article, the author considers the Spanish position regarding the concept of a permanent establishment and whether the Spanish concept conforms to the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative or is simply an erroneous interpretation of the provisions of article 5 of the OECD Model.


The Spanish General Anti-Abuse Rule

Carlos Palao Taboada

The author, in this article, considers the evolution, together with the implications, of the Spanish general anti-abuse rule since it first introduction in 1963, with especial reference to the current version of 2004, as amended in 2015.


Tax Transparency and Disclosure in Spain

Fernando Serrano Antón

This article deals with the various tax transparency and disclosure provisions in Spanish law with particular reference to disclosure, exchange of information, and the OECD/G20 Base Erosion and Profit Shifting initiative and EU directives and law.


Encouraging Research and Development (and Innovation) in the Spanish Tax System

María Teresa Soler Roch and Elizabeth Gil García

This article examines the tax system for research and development (and innovation) (R&D (&I)) in Spain. Generally, the Spanish tax system encourages R&D (&I) by granting a wide range of incentives with regard to R&D (&I), as companies may benefit from input and output incentives in respect of such activities.

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