Spanish Supreme Court Confirms Position on Interpretation and Application of Tax Treaties

The Spanish Supreme Court issued a decision on 23 September 2020 concerning the interpretation and application of Spain's tax treaty with Switzerland in relation to beneficial ownership. This follows an early decision issued in March 2020 in relation to permanent establishment provisions, with a similar result ({News-2020-06-11/T/2-previous coverage}). In both cases the Court has essentially r…
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