Tax
Pillar 2 in Poland- what is worth remembering in 2026?
The global minimum tax is now an integral part of the European Union's tax regulations. This article will briefly discuss the key steps that need to be taken in order to properly settle the global and domestic top-up tax, as well as the administrative obligations resulting from the implementation of the Pillar 2 Directive into the Polish legal system.The public CbC: first application in Spain of the new obligation of “corporate transparency”
The obligation to publish the so-called “country-by-country report” (known as “public CbCR”) affects multinational groups and independent companies whose consolidated revenues exceed 750 million euros in each of the last two consecutive years. Spain has some relevant peculiarities in the transposition of this obligation that should be considered in its first application.Spain: Examination of new administrative principles on conflicts in the application of tax provisions and sham transactions
Although the Supreme Court has already concluded that the “classification,” “conflict in the application of tax provisions,” and “sham transaction” rules are not interchangeable, TEAC held recently that a sham transaction proceeding can be initiated in relation to a transaction meeting the requirements set out in the General Taxation Law (LGT) for a conflict.Related-party transactions are consolidated as a preferential point of attention for the Public Treasury
In recent years, we have witnessed a notable increase in the investigation and verification of transfer pricing issues by the Spanish tax authorities. We review the most common controversies in this area, outlining potential recommendations.Taxation of royalties: the Supreme Court gives primacy to the Directive over agreements
In a recent and controversial judgment, the Supreme Court affirms that when the Interest and Royalties Directive cannot be applied because the recipient of the royalties is not the “beneficial owner”, the withholding tax rate established in the Spanish domestic non-resident income tax regulations must be applied, rather than the reduced rate of the corresponding Tax Treaty for avoiding double taxation, given the primacy of EU law.SAFE: Mechanism for financing the defense sector in Poland by the European Union
The European Union has taken an unprecedented step towards strengthening its common security and defence policy. In this article, we discuss the main objectives of the programme, its legal instruments and the tax implications for entities participating in defence procurement.The EU promotes the elimination of the VAT exemption on short-term rentals
Directive (EU) 2025/516 introduces a significant reform in the VAT scheme applicable to short-term rentals, which is set to take effect on July 1, 2028. The reform will mean that rentals of accommodation to the same person for a maximum of thirty nights will be subject to VAT, on the basis that this type of rental has a similar function to the hotel sector. In addition, the role of digital platforms in collecting VAT is strengthened. It will be necessary to closely monitor the adaptation of this Directive to Spanish law in order to determine its final scope.Portugal: Exceptional extension of tax deadlines in municipalities affected by Storm Kristin
Following the state of calamity caused by storm Kristin, the Portuguese government decided to allow taxpayers and certified accountants with a registered office or domicile in the affected areas to fulfil their tax obligations without the imposition of interest or penalties until the end of April.