Substance requirements in ETVE companies in a post-beps world
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1 1 Substance requirements in ETVE companies in a post-beps world GUADALUPE DÍAZ-SÚNICO BUENOS AIRES, 4 DECEMBER 2017
2 04/12/ IN A NUTSHELL: Spain offers a very attractive holding tax regime (ETVE) and is not a tax haven jurisdiction Spain is the jurisdiction with the most Tax Treaties and Bilateral Investment Treaties in force with Latin America
3 04/12/ SPANISH TREATY NETWORK Albania Croatia Iceland Moldova Slovenia Algeria Cuba India Morocco South Africa Andorra Cyrpus Indonesia New Zeland South Corea Argentina Czech Republic Iran Nigeria Sweden Armenia Denmark Ireland Norway Switzerland Australia Dominican Republic Israel Oman Thailand Austria Ecuador Italy Pakistan The Netherlands Barbados Egypt Jamaica Panama Trinidad and Tobago Belgium El Salvador Japan Philippines Tunisia Bolivia Estonia Kazakhstan Poland Turkey Bosnia Herzegovina Ex URSS Kuwait Portugal United Arab Emirates Brazil Finland Latonia Romania United Kingdom Bulgaria France Lithuania Russia United States Canada Georgia Luxemburg Saudi Arabia Uruguay Chile Germany Macedonia Senegal Uzbekistan China Greece Malaysia Serbia Venezuela Colombia Hong Kong Malta Singapore Vietnam Costa Rica Hungary Mexico Slovakia
4 04/12/ AGREEMENTS FOR EXCHANGE OF INFORMATION Andorra Aruba Bahamas Bermudas* Cayman Island* Cook Island* Curazao EE.UU. (FATCA) Guernsey* Isle of Man* Jersey * Macao* Monaco* Saint Lucia* Saint Marino Saint Martin Saint Vincent and the Grenadines (*) Agreements not in force.
5 BLACK-LISTED JURISDICTIONS Bahrain Brunei Cyprus Gibraltar Anguilla Antigua and Barbuda Bermuda Cayman Islands Cook Islands Republic of Dominica Grenada Fiji Channel Islands (Guernsey and Jersey) Islas Malvinas Isle of Man Mariana Islands Mauritius Montserrat Republic of Nauru Solomon Islands Saint Vincent and the Grenadines Saint Lucia Turks and Caicos Islands Republic of Vanuatu British Virgin Islands United States Virgin Islands Hashemite Kingdom of Jordan Republic of Lebanon Republic of Liberia Principality of Liechtenstein Macau Principality de Monaco Sultanate of Oman Republic of Seychelles
6 04/12/ THE IDEAL HOLDING REGIME ETVE No taxation on paid-in dividends No taxation on paid-in capital gains No taxation on paid-out dividends/gains No capital tax Financing expenses generally deductible Wide tax treaty network Stable and reliable regime Protection of the investment (Bilateral Investment Treaties)
7 04/12/ Domestic legislation & treaty LATAM 0% WT Dividends: 0% Withholding tax (WT) Capital gains on the sale of ARG subsidiaries: 13,5%/15% (10% treaty limits) ETVE 0% Spanish Tax (dividends and capital gains) 0% WT/10%WT Argentina Argentinean Tax:35%
8 04/12/ COMPARISSON. LATAM Argentina Brazil Chile Colombia Mexico Dividend DTT WT 0% - 10% - 15% 0%-10% - 15% 5% - 10% 0% - 5% 0% - 10% ETVE Spanish CIT 0% 0% 0% 0% 0% WT exit to shareholder Minimum net dividend 0% 0% 0% 0% 0%
9 04/12/ ETVE requirements BUSINESS PURPOSE: To manage the shareholdings in non-spanish subsidiaries (other activities allowed). SUBSTANCE: Need of human and material resources to manage the shareholdings in non-spanish subsidiaries. FORM OF THE ETVE: Sociedad Limitada, Sociedad Anónima (per ser corporation) or Sociedad Comanditaria. Need to have nominative shares. FILINGS: A notification must be filed before the Spanish Tax Authorities.
10 04/12/ Substance and BEPS/GAAR The substance requirement and the BEPS Project/MLI Action 6 BEPS (Treaty abuse) Preamble and Principal Purpose Test (PPT) in the MLI The substance requirements and the effective management (article 4 Tax Treaties) The substance requirements and the GAARs. The substance requirements and the genuinity of the structure. A safe harbor objective list? Facts and circumstances? Case by case approach?
11 04/12/ Guidelines for good practices: Directors Decisions Bank accounts Administration Dividends policy Personal means Material means
12 04/12/ Restructuring opportunities to achieve BEPS compliant structures: migrating holding companies from black-listed countries to Spain No capital tax No winding-up of the company: continuance of the legal personality. No taxable capital gain for the company or the shareholders. No tax heaven No tax heaven Tax heaven ETVE Branch ARG* ARG* Branch ARG* ARG* *Qualifying subsidiaries
13 13 Guadalupe Díaz-Súnico Este documento es meramente expositivo y debe ser interpretado conjuntamente con las explicaciones y, en su caso, con el informe elaborado por Cuatrecasas sobre esta cuestión This document is merely a presentation and must be interpreted together with any explanations and opinions drafted by Cuatrecasas on this subject Este documento é uma mera exposição, devendo ser interpretado em conjunto com as explicações e quando seja o caso, com o relatório/parecer elaborada pela Cuatrecasas sobre esta questão
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Kentucky Cabinet for Economic Development Office of Workforce, Community Development, and Research
Table 2 Kentucky s Exports to the World -- Inclusive of Year to Date () Values in $ Thousands 2016 Year to Date Total All Countries $ 29,201,010 $ 30,857,275 5.7% $ 20,030,998 $ 20,925,509 4.5% Canada
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COMMONWEALTH OF DOMINICA
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Council of the European Union Brussels, 22 November 2018 (OR. en)
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