The impact of BEPS in the taxation of private equity Abstract

The impact of BEPS in the taxation of private equity

Abstract:

This article examines the effects that the recent Base Erosion and Profit Shifting (BEPS) Project is having on the taxation of private equity.
Specifically, it analyzes the changes introduced by the recent reforms of the Corporate Income Tax Law that have stemmed from this Project as well as the effects that Actions 6 and 7 on treaty abuse and the avoidance of permanent establishment status may have on the Spanish tax treaty.

Keywords: BEPS, Tax treaties, Anti-abuse, Corporate Income Tax Law, Interest deductibility.