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Audiencia Nacional confirms application of ‘Danish cases’ doctrine to non-resident income tax exemption of interest payments to EU residents

icon 28 of November, 2024

For the Audiencia Nacional, the CJEU’s stance in the Danish cases is automatically applicable to the exemption of interest paid to EU residents, even if the national legislative provision does not expressly refer to beneficial ownership clauses. 

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Autor/s

Eduardo Martínez-Matosas – Partner

Luis Cuesta – Senior Associate

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Tipology

Analysis

Areas and sectors

Tax