Tax
Garrigues wins three awards from 'El Confidencial', including best law firm
At the gala presentation of the II Edition of the El Confidencial Business Lawyer Awards, held last night in Madrid, Garrigues won three awards: Best Law Firm, Best Tax Team and Best Firm Lawyer by Fernando Vives, executive chairman of the firm.Peru: The deadline is approaching for Peruvian consortia, funds and trusts to submit the declaration of ultimate beneficial owner
Any Peruvian or foreign company or investor who directly or indirectly participates in the results or exercises effective control of the legal arrangement shall take into account the declaration to be made within the first 20 days of July 2024.Spain: Time of imputation of refunds of taxes declared unconstitutional
The Spanish Constitutional Court has been limiting the temporal effects of the unconstitutionality of tax rules, in the case of non-consolidated situations, to the date on which the corresponding ruling is handed down, with an expansive interpretation of this concept of “non-consolidated situation”. We review what these limitations consist of and how to allocate any refunds obtained.Portugal: PTA has decided that Advance Pricing Agreements are the suitable mechanism to determine the transfer pricing method and the arm's lengh pricing, under intragroup service agreements
The Portuguese Tax Authorities (PTA) decided, in the context of a Binding Information Request (PIV) –Case no. 22442–, that this is not the appropriated approach for determining the transfer pricing method nor the arm’s length pricing between related parties under an intragroup service agreement. Instead, PTA considered that entering into an Advance Pricing Agreement (APA) is the suitable mechanism for these cases.China’s first attempt for Advance Tax Ruling: trail implementation in Shanghai
Shanghai introduces a trial Advance Tax Ruling (ATR) system, a significant step in China's tax administration. ATR, common in countries like Spain and the U.S., allows enterprises to seek formal tax opinions on future complex tax matters, enhancing certainty. The ATR applies to corporate taxpayers in Shanghai, though its applicability to non-resident taxpayers is subject to further confirmation with the in-charge tax authority.