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| Author: | Raventos, S. |
| Title: | CFC provisions introduced |
| Journal: | European Taxation
1995 : VOL. 35:5, p. 164-167 |
| Index terms: | SPAIN COMPANY TAXATION COMPANY CONTROL |
| Language: | eng |
| Abstract: | Controlled foreign corporation provisions became effective on 1 January 1995 and apply both to resident individual and corporate taxpayers. The tax authorities did not wait until the publication of the forthcoming Corporate Tax Law introduce the CFC provisions. Law 42/1994 of 30 December on "tax, administrative and social measures" contains the new rules. The provisions are clearly inspired by those in the United States and Germany, but, although the bill proposed by the Ministry of Economy and Finance was very severe, amendments presented by the political parties in parliament and the powerful Spanish Banking Association have considerably softened the final result. Because of the many amendments, the ultimate CFC rules are much more confusing than they were in the bill. It will also be very difficult for them to be applied and controlled. |
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