Skip to main content

Newsletter

Don't miss out on information about the foundation's activities! Leave us your email and you will receive in your inbox all the news about our work.
Visual theme selection
Light Dark

Publications

We edit our works, and we like to give them the widest possible dissemination, facilitating free and open access to their full text. We invite you to its analysis
Imposición Mínima Global: Normas para su aplicación, evaluación de su impacto sobre el sistema tributario doméstico e internacional
Download (3.05 MB)
December 2025

Imposición Mínima Global: Normas para su aplicación, evaluación de su impacto sobre el sistema tributario doméstico e internacional

El pasado mes de julio se editó este libro, que recoge el trabajo de un amplio grupo de expertos, fundamentalmente profesionales del asesoramiento fiscal, junto con dos expertos que han ejercicio la función pública en el terreno de la Administración, y dos profesores universitarios. Combinación de perfiles muy recomendable para el análisis de esta nueva modalidad de tributación, significativamente novedosa. El libro es el reflejo de un enfoque tradicional en los trabajos de la Fundación Impuestos y Competitividad, ofreciendo de un lado una aproximación muy pragmática, que aspira a repasar los aspectos necesarios para que los grupos  empresariales afectados puedan evaluar la existencia o no de su obligación de aplicación…

La reciente Jurisprudencia sobre la doctrina del “doble tiro”.
Download (164.43 KB)
May 2025

La reciente Jurisprudencia sobre la doctrina del “doble tiro”.

Como en anteriores ocasiones, el desarrollo del  Ciclo de Charlas Coloquio organizado por la Fundación Impuestos y Competitividad propicia, como reflejo del contenido de alguna de esas charlas, documentos de interés. En esta ocasión, y tras su exposición el pasado 7 de mayo, el profesor Félix Vega Borrego (Universidad Autónoma de Madrid), amablemente nos ha autorizado a compartir la presentación sobre este asunto, que utilizó como hoja de ruta de su ponencia. El documento refleja el análisis de la STS más reciente, que ha modificado la postura tradicional del mencionado Tribunal, y abierto una notable polémica al respecto, sobre la teoría del “doble tiro” que tiene un peso importante en…

Municipal taxation: Assesment and proposals for reform
Download (2.21 MB)
March 2025

Municipal taxation: Assesment and proposals for reform

As a  result of several months of work, in October 2024 Fundación Impuestos y Competitividad published its first work dedicated exclusively to the study of the local tax system. The book does not analyse the issue of local authority financing,  focusing on specific tax problems, as a field of the Foundation’s research work. In this context, and with the usual philosophy underlying other projects, there is a broad analysis of the subject, which in no event aims to be all-encompassing, with a diagnosis of  possible  problems and proposals for solutions As the title of the work bears out, the authors generally agree on the need for a deep reform of…

Main cases admitted for processing in cassation in 2024
Download (1.17 MB)
March 2025

Main cases admitted for processing in cassation in 2024

Although it is not a document generated by Fundación Impuestos y Competitividad, since it was drawn up by Judge Sandra González de Lara Mingo -for  the presentation of her first paper at the Ciclo de Charlas Coloquio  organised during 2025-, we consider its content to be very useful and so worth sharing on the Foundation’s website. Along with interesting information on recent changes in the SC, there is a valuable summary of the work of the First Section of the Third Chamber of the SC, and therefore of the writs of admission issued, together with  details of the most interesting tax related matters that have been admitted for processing in…

Fiscal response to the crisis
Download (2.32 MB)
December 2024

Fiscal response to the crisis

In June 2024, the research work promoted by Fundación Impuestos y Competitividad on “Tax reforms in response to the crisis” was completed. The work ended with the publication of the book titled  “Reacciones fiscales ante la crisis”  (Fiscal response to the Crisis). The title in itself reflects the critical assessment made of the regulatory changes and novelties that have arisen in recent years in relation to the tax system,  a system whose scope has even been “circumvented” by the legislator in order to include figures that are not meant to qualify as taxes, with the clear promotion of non-tax compulsory payments. Fundación Impuestos y Competitividad now makes the full text…

European Law and the Spanish Tax System, an in-depth assessment
Download (2.97 MB)
February 2024

European Law and the Spanish Tax System, an in-depth assessment

In keeping with the Foundation’s proven interest in international taxation, this project was completed during 2022 and 2023, and the end document titled “European Law and the Spanish tax system, an in-depth assessment”  was published in October 2023, coinciding with Spain’s six-month presidency of the Council  of the European Union. In carrying out this project, the usual group of professionals from the firms on the Board of Trustees, coordinated on this occasion by PwC, was joined by important representatives from academia, such as Mr Aitor Navarro Ibarrola (Universidad Carlos III), Mr Andrés Báez Moreno (Universidad Carlos III), Ms Gemma Patón García (Universidad de Castilla La Mancha) and Ms Saturnina Moreno…

Tax reform: Comments on the draft bill establishing a supplementary tax to ensure a global minimum level of taxation in multinational groups and large spanish groups
Download (641.38 KB)
January 2024

Tax reform: Comments on the draft bill establishing a supplementary tax to ensure a global minimum level of taxation in multinational groups and large spanish groups

As part of the ongoing monitoring of the production of tax legislation, the Trustees of Fundación Impuestos y Competitividad have presented their preliminary observations on the aforementioned draft bill which aims to complete the transposition of European Directive 2022/2523 of the Council of 15 December 2022. This process which ends in what has become known as Pillar II, taking as a basis the BEPS action 1 project “Tax challenges arising from the digital economy for multinational enterprises”, is undoubtedly an essential element in the new configuration of corporate income tax and a very important step in the definition of “global taxation for multinational companies”. Considering the significance of this regulation,…

Final report on compliance by the Spanish Government with the commitments assumed under component 27 of the Recovery, Transformation and Resilience Plan (P.R.T.R.)
Download (381.38 KB)
January 2024

Final report on compliance by the Spanish Government with the commitments assumed under component 27 of the Recovery, Transformation and Resilience Plan (P.R.T.R.)

The Secretariat of State for Finance (presidency of the A.E.AT.) requested the collaboration of the Fundación Impuestos y Competitividad in analysing and evaluating the measures adopted under the commitments assumed by Spain in Component 27 of the Recovery, Transformation and Resilience Plan and specifically, the measures adopted by Law 11/2021 on “measures to prevent and combat tax fraud”. In 2022 this collaboration was extended to the “interim evaluation” and to the definitive evaluation in 2023. The novelty in this second year was that together with the follow-up of the measures adopted under Law 11/2021 on “measures to prevent and combat tax fraud”, the Foundation was asked to make contributions and…

Tax litigiousness: Alternative means for dispute resolution and facilitation measures
Download (646.19 KB)
May 2023

Tax litigiousness: Alternative means for dispute resolution and facilitation measures

Work on this project was carried out over an extended period of time, consistent with the intention to search for pragmatic solutions enabling effective implementation, which characterised its approach. For this reason, following an initial approximation to the issues analysed by each of the authors of the chapters of the book, a series of seminars were held to share the first draft and proposals on each matter under review.  Namely: These Seminars were attended by the representatives of various public and private institutions – the relevant social partners in tax. Their opinions which were expressed in in the debates which took place in each seminar, helped to complete and improve…

Tax reform: Observations on the transposition into spanish law of directive (EU) 2022/ on ensuring a global minimum of taxation for enterprise groups
Download (186.99 KB)
March 2023

Tax reform: Observations on the transposition into spanish law of directive (EU) 2022/ on ensuring a global minimum of taxation for enterprise groups

As part of the ongoing monitoring of the production of tax legislation, the Trustees of Fundación Impuestos y Competitividad have presented their preliminary observations on the transposition of the aforementioned Directive. Based on what was the BEPS Action 1 Plan, “Tax challenges arising from the digital economy for multinational enterprises” and within the OECD’s work in this regard, namely, so-called Pillar I and Pillar II, the EU has adopted its own initiative in the field of Pillar II. Since the transposition of the aforementioned Directive into Spanish law is mandatory, it is essential to carefully monitor the ongoing process, during which the Foundation’s Trustees will attempt to contribute to the best transposition…

Report on compliance by the Government of Spain with the commitments undertaken in component 27 of the Recovery, Transformation and Resilience Plan (R.T.R.P.)
Download (550.86 KB)
January 2023

Report on compliance by the Government of Spain with the commitments undertaken in component 27 of the Recovery, Transformation and Resilience Plan (R.T.R.P.)

The Secretary of State for Finance (President of A.E.A.T.) requested the collaboration of Fundación Impuestos y Competitividad for the analysis and evaluation of the measures adopted in accordance with the commitments undertaken by Spain in Component 27 of the Recovery, Transformation and Resilience Plan, specifically the measures adopted by Law 11/2021, on “measures to prevent and combat tax fraud”. The result of said collaboration was the report that is now presented in these pages, following the express approval of the Secretary of State. It is true that the “Interim Evaluation” report issued last December by the Secretary of State refers extensively to the Foundation’s comments and evaluations; which, in the…

Current issues concerning tax application procedures and proposals for improvement
Download (1.34 MB)
December 2022

Current issues concerning tax application procedures and proposals for improvement

This document, which was published by the Foundation last June 2022, is organised into 13 chapters, the last of which was written by Maximino Linares (EY Abogados, the firm coordinating the project) and aims to reflect the primary considerations of previous chapters and underscore the proposals for improvement. True to the pragmatism of the Foundation’s projects, these proposals for improvement are incorporated into the content of this work and are generally clearly connected with upholding legal certainty and the efficiency of administrative procedures, which should be the principles at the centre of tax proceedings. The project does not aspire to address all tax procedural matters and so includes no references…

Tax reform: observations addressed to the commission for the preparation of the white paper on tax reform
Download (859.93 KB)
November 2021

Tax reform: observations addressed to the commission for the preparation of the white paper on tax reform

As part of the continuous monitoring of the drafting of rules and regulations on tax matters, the Board of Trustees of Fundación Impuestos y Competitividad has undertaken to participate in the Commission’s open public consultation and is grateful for the opening of said process. The participation in said open public consultation is an opportunity for the Foundation to fulfil its own foundational purposes, at the same time collaborating with the Committee and with the governmental initiative that has fostered this process. It is evident that when doing so it will endeavour to be consistent with its statutory claim of finding more positive solutions “for the benefit of the competitiveness of…

Transfer tax and stamp duty: Current situation and future proposals
Download (2.12 MB)
November 2021

Transfer tax and stamp duty: Current situation and future proposals

In November 2021, approximately one year ago, this work was published focusing exclusively on the consideration of transfer tax and stamp duty, a State tax whose collection has devolved to the Autonomous Communities; for which its importance from the viewpoint of collection is not insignificant. The work, with an equally complex structure, to which free access now offered, responds to the indisputable structural and technical complexity of this tax, which actually comprises three different legal concepts: transfers for consideration, corporate operations and transactions evidenced by legal documentation. The book is divided into 17 chapters, ordered in accordance with the following structure: The work seeks to analyse the most controversial issues…

State aid in relations to taxes: Spanish experience and current context
Download (1.55 MB)
July 2021

State aid in relations to taxes: Spanish experience and current context

In July 2021, the Fundación Impuestos y Competitividad published this work, the result of an extensive effort of several months by officials of the European Commission, university professors and several professionals from the firms that make up the board of trustees, with a broad vision on the subject, derived from their specialization in Tax Law, but also in Public International Law and Competition Law. This vision, from different perspectives, is reflected in the content and structure of the book, which covers a wide variety of issues on the subject; with an abstract vision, but also with particular attention to those State aid cases that have had in recent years a…