Spanish CFC Rules Stray from the EU Anti-Tax Avoidance Directive (2016/1164)

This article discusses the main aspects of the Spanish CFC rules, which, following their recent amendment in connection with the transposition of the EU Anti-Tax Avoidance Directive, may give rise to problems of compatibility with EU law from two angles: (i) compliance with the ATAD transposition obligations; and (ii) respect for the fundamental freedoms of the European Union.