Tax

Garrigues

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  • Mexico: Mandatory adoption of the electronic customs value statement Is postponed and will take effect according to each customs regime

    The Tax Administration Service (SAT) extends the deadline for adopting the electronic customs value statement and sets out a phased schedule based on the customs regime. Importing companies now have more time to adapt their processes and gather the required documents and information before the obligation takes effect. 

  • Portugal Indirect Taxes Newsletter – N.º 6

    This edition highlights the latest developments in indirect taxation, with a special focus on the clarifications issued by the Portuguese Tax Authority (AT) regarding the measures approved under the Housing Program, namely on the application of the reduced VAT rate to construction and rehabilitation works, the partial VAT refund regime, and the reverse charge mechanism applicable on the acquisition of construction services, as well as the rules for invoice rectification and VAT regularization.  

  • China repeals the historical tax exemption on dividends paid to foreign individuals: key implications for Spanish investors

    China has ended a long-standing tax exemption on dividends for foreign individual investors and will now impose a 20% withholding tax. Spanish tax residents should rely on the Spain-China tax treaty to mitigate the tax impact and reduce the risk of double taxation.

  • The tax authorities cannot adjust a taxpayer’s position through alternative exclusionary arguments

    According to the Supreme Court, it is not valid for tax auditors to deal with a finding of fraud upon the law potentially being set aside by providing other adjustment alternatives in the assessment. 

  • Garrigues wins seven awards at ITR Europe Tax Awards 2026

    The firm was named CJEU Firm of the Year and received industry honors in Spain and Portugal

  • Transfer pricing regulations are not valid to discuss the deductibility of expenses incurred vis-à-vis third parties

    In a groundbreaking ruling, the Supreme Court concludes that the tax authorities cannot use transfer pricing regulations to deny the deduction of expenses that a Spanish company has incurred with third parties, even if the underlying business decision has been taken by the group.    

  • Portugal grants additional time for the submission of Model 62 filing (Pilar Two) in regards FY2025

    Order No. 114/2026-XXV, of 1 September has been published, extending the deadline for filing the Model 62 return in respect of fiscal year 2025, allowing it to be filed, without any surcharges or penalties, until the last day of the 12th month following the end of the relevant fiscal year.

  • Change of hotel operator and transfer of undertakings: a critical issue

    A change of operator can trigger a transfer of undertakings with significant legal implications for the new operator, especially in the fields of tax and employment.    

  • Poland: Current status and key proposals of Tax Deregulation 2.0

    The Polish government has presented a package of proposals entitled “Deregulation 2.0” concerning tax administration and tax law. Their stated aim is to simplify tax settlement and increase legal certainty by improving relations between the tax administration, taxpayers and entrepreneurs. Three areas have so far been included as separate projects in the Council of Ministers’ work schedule, but the draft legislation has not yet been published. These measures have only been announced so far, and their scope and timetable may change. 

  • Spain - The taxpayer's protected digital domicile: a missing legal framework

    The growing digitalisation of taxpayers' personal and professional activity raises new challenges for the protection of privacy and calls for the recognition and regulation of a genuine “protected digital domicile”, distinct from the physical domicile and from the fiscal domicile.