CJEU rules that Spain’s penalty regime for failure to report overseas assets and rights to tax authorities is contrary to EU law

Executive summary
On 27 January 2022, the Court of Justice of the European Union (CJEU) published a resolution (the Resolution) concerning the regulation of the obligation for Spanish tax residents to provide information with respect to overseas assets and rights (i.e., Form 720) and its penalty regime.
The Resolution does not declare the obligation to provide information concerning assets and right…
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