Spain Issues Regulations for the Global Minimum Tax Act
On April 2, 2025, Spain issued Regulations for the application of the Global Minimum Tax Law. This includes a number of aspects of the OECD Administrative Guidance.
The Treatment of Permanent Establishments under Pillar Two
Permanent Establishments (PEs) are subject to a number of specific rules under Pillar Two in order to apply the general provisions to them. Key issues are what is a PE under Pillar Two? where is it located? and how are income and taxes allocated to it?
