September 2022
Royal Decree-Law 17/2022, of September 20, has been published, adopting urgent measures in the field of energy, in the application of the remuneration regime to cogeneration facilities and temporarily reducing the rate of Value Added Tax applicable to deliveries, imports and intra-community acquisitions of certain fuels.
Information provided in the taxpayer calendar on declarations and self-assessments whose submission deadline ends in September
For the purposes of the provisions of article 206.bis of Law 58/2003, of December 17, General Tax Law and in accordance with the provisions of article 194.6 of the General Regulations on actions and procedures for tax management and inspection and development of common rules for procedures for the application of taxes, approved by Royal Decree 1065/2007, of July 27, a copy of the report of the Advisory Committee on the conflict in the application of the tax rule relating to the taxpayer "PQ HOLDING" is hereby published.
For the purposes of the provisions of article 206.bis of Law 58/2003, of December 17, General Tax Law and in accordance with the provisions of article 194.6 of the General Regulation of the actions and procedures of tax management and inspection and development of the common rules of the procedures for the application of taxes, approved by Royal Decree 1065/2007, of July 27, a copy of the report of the Advisory Commission on the conflict in the application of the rule relating to the taxpayer "M CORPORATION" is hereby published.
The Report states that there is a conflict in the application of the tax rule in a case of transfer by a US company of its Spanish subsidiary through a chain of operations between group companies, avoiding taxation by relying on the provisions of the Protocol to the Convention between the Kingdom of Spain and the United States of America to avoid double taxation and prevent tax evasion with respect to income taxes.