Financing Activities: Hybrid Mismatches and the Tax Deductibility of Interest in Spain
Journal
Country
Spain
Published Date
Issue
Bulletin for International Taxation 2016 (Volume 70), No. 8
Document
This article discusses the provisions of the Spanish Ley del Impuesto sobre Sociedades (Corporate Income Tax Law) regarding the tax deductibility of interest and the neutralization of the tax effects of hybrid instruments. In doing so, both domestic rules and the recommendations of the OECD and European Union are considered.