Publications

In a resolution dated 27 September 2024, the Central Economic-Administrative Court analysed the burden of proof in the special VAT refund scheme for entrepreneurs or professionals who are not established in the Territory of Application of the Tax (TAT), but who are established in the European Union, the Canary Islands, Ceuta or Melilla. In accordance […]

On March 11, 2025, the European Commission adopted the new “VAT in the Digital Age” (ViDA) package, whose implementation will be progressively rolled out until 2035. This new framework introduces digitisation based on e-invoicing to combat tax evasion techniques such as carousel fraud, with estimated savings in compliance costs and measures to reduce the black […]

ChatGPT, Gen AI, Machine Learning – just to name a few buzzwords – are new technologies that are already indispensable in our daily lives. Artificial Intelligence (AI), as a general term encompassing this vast field, is playing an increasingly important, if not irreplaceable, role in both private and professional environments and in a very cross-cutting manner. […]

Royal Decree-Law 4/2025: Promotion of Business Continuity and Accounting Adjustment: Temporary suspension of the grounds for dissolution due to losses and extension of the deadline for restating the 2024 annual accounts.   With the recent publication of Royal Decree-Law 4/2025 of 8 April (published in the BOE on 9 April 2025), the Spanish government is […]

The Government has published a new version of the draft Royal Decree that will regulate the mandatory electronic invoicing between businesses and professionals (B2B), as part of the development of Law 18/2022 on the creation and growth of companies. This version introduces significant changes compared to the previous version (June 2023). It is currently in […]

We hope the following information is of your interest.   Please keep in mind, that the deadline for filing the following declarations is April 21st, 2025: Form 303, quarterly VAT return. Filing deadline for taxpayers included in the Immediate Supply of Information (“SII”) system is April 30th, 2025. Form 349, (quarterly/monthly) EC Sales List (Intra-Community […]

Where there is ‘unity of decision-making’, national tax authorities cannot refuse to recognise the group, even if this reduces their tax revenue.   Intra-group transactions are exempt from VAT, according to a recent ruling by the Court of Justice of the European Union (CJEU). The exchange of goods or services between different business units does […]

On 17 March, the Official State Gazette (the “BOE”) published the 2025 Annual Tax and Customs Control Plan, which sets out new tax control guidelines for the coming year. In particular, the transfer pricing control will be intensified, with a focus on improving tax compliance. Automated risk analysis tools, greater specialisation and international cooperation will […]

Artificial Intelligence (AI) is transforming our industries – and our daily lives – by providing innovative solutions and greater efficiency in a wide range of processes. But with these advances come new and growing cybersecurity risks, threats that must be addressed to ensure the integrity of AI systems and the data on which they rely. […]

Case C-184/23 before the Court of Justice of the European Union (CJEU) concerns the application of VAT to intra-group transactions under Directive 2006/112/EC. Specifically, it concerned the case of a German public-law foundation ‘S’, which was the parent company of a university (which managed a university medical centre) and a company called ‘U-GmbH’.   In […]

Non-resident taxpayers who move to Spanish territory and who, as a result of this move, acquire tax residence in Spain, may opt to be taxed under the special regime for posted workers, better known as the Beckham Law.   Broadly speaking, the regime allows the taxpayer to apply a territorial criterion for tax purposes for […]

Pursuant to Royal Decree 1007/2023 and the Ministerial Order published on 10/28/2024, which introduce new obligations regarding invoicing software and the Verifactu system versus non-verifiable systems, we would like to update recent developments confirmed by the Spanish Tax Agency (AEAT) in the informative session of 01/21/2025, detailed in section 4 of this circular.   1. […]

Pursuant to Royal Decree 1007/2023 and the Ministerial Order published on 10/28/2024, which introduce new obligations regarding invoicing software and the Verifactu system versus non-verifiable systems, we would like to update recent developments confirmed by the Spanish Tax Agency (AEAT) in the informative session of 01/21/2025, detailed in section 4 of this circular. 1. Who […]

Electronic invoicing is at the centre of a regulatory evolution in Spain and in the European Union. This change responds to key objectives such as the digitalisation of processes, tax control and the fight against late payment. The most relevant aspects of the recent reforms and their impact on the business fabric are analysed below. […]

On 2 January, the Official State Gazette (BOE) published Organic Law 1/2025 on measures to improve the efficiency of the Spanish National Judicial Service. The regulation entails the abolition of the Golden Visa regime, rendering ineffective Articles 63 to 67 of Law 14/2023 of 27 September, which supported entrepreneurs and their internationalisation by regulating residence […]