The recent order of the National Court of March 23, 2021, has urged a question of constitutionality on Royal Decree-Law 3/2016, whose resolution could affect all or part of its content.
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Salvador Balcells i Iranzo
One of the things Mr. Balcells like most about his job is when you get a safe, legal and fair tax situation for the sake of the taxpayer's tranquility and economy, both in previous structuring and planning, and when certain criteria have to be defended before Tax administration.
As a lawyer, he always try to put himself in the place of the one who asks for advice, so that all the options or alternatives that are considered as solutions, are those that would adopt at a personal level if the interested party is himself.
- Restructuring processes (mergers, splits, exchanges, contributions of branches of activity, ...).
- Procedures for inspection, collection and tax management.
- Resources before the Administration, the economic-administrative Courts and the administrative litigation courts.
- Management of due diligence prior to processes of purchase, acquisition, merger, ...
- Analysis of planning and systems of tax optimization (consolidation taxation, assessment of the application of different tax deductions, possible use of the various existing special regimes, ...)
- Fiscal and accounting closures for the tax period affected
- Study of the combinations of Spanish and Andorran taxation in the field of natural persons and companies and compliance with formal and legal requirements.
The Accounting and Auditing Institute (hereinafter ICAC) has confirmed in a query that literally analyzes that the owners will not have to pay taxes for the income not received due to the reductions agreed in the rental contracts derived from COVID-19.
As is well known, the AEAT has its own notification regime in its relations with the companies that is developed through the so-called authorized electronic address (DEH).