Spanish National Appellate Court allows foreign foundations to apply the special tax exemption regime provided for resident foundations

2. The Facts
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The facts can be summarised as follows:
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• In the fiscal year 2006, Stifterverband Für Die Deutsche Wissenschaft e.v (the «Foundation»), a German based non-profit entity sold a real estate property located in Spain and paid Spanish Non-Resident Income Tax («NRIT») on the capital gains obtained…