Spain: Supreme Court Limits Tax Authority on Holding Contributions
On 14 October 2026, the Spanish Supreme Court (Sala de lo Contencioso-Administrativo) issued a landmark ruling (Sentencia 1245/2026) that significantly curtails the tax administration’s ability to challenge non-cash contributions to holding companies under the anti-avoidance provision of Article 89 of the Corporate Tax Law (LIS). The Court held that the mere absence of an explicit
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