The purpose of this paper is to analyze, in the light of its regulatory evolution, the Spanish experience regarding the application of the so-called special regime for groups of entities in Value Added Tax. As stated throughout the study, we believe that the regulation of the special regime carried out by the Spanish legislator does not comply with art. 11 of the VAT Directive, since is not built a new and unique taxable person in the Tax. Furthermore, not even the basic modality of the special regime can be classified as a true group regime, since it does not eliminate operations between them. And neither does the “advanced” modality. All this without prejudice to recognizing the effort made by the Spanish legislator when perfecting the regulation of this special regime.
Source Studi Tributari Europei
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