Espagne : la cour rejette la demande d'une filiale tendant à une déduction fiscale de taxe fiscale relative à une transaction intra-groupes
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La Cour nationale espagnole a rejeté l'appel de services intra-groupe contre les évaluations des autorités fiscales qui avaient estimé ces services "limité et inadéquat". En l'espèce, l'autorité fiscale espagnole avait publié des évaluations et augmenté la taxe payable pour inclure des services et des dépenses allouées à ce type d'accords intra-groupes. La filiale a soutenu qu'elle devait bénéficier d'une déduction fiscale. La cour a refusé d'accorder cette déduction pour les honoraires de gestion au motif que la société n'avait pas produit la preuve que les services fournis et que les...
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