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Ruling impacts collective investment undertakings from third-party countries
The Spanish Supreme Court, in judgments of December 17 2020 and January 21 2021, reiterated that the fundamental freedom of capital movement had been infringed by the inconsistent tax treatment afforded under Spanish law to certain investors (i.e. investment funds or pension funds) resident in third-party states outside the EU or the EEA compared to resident investors.
The Supreme Court considered whether, as the state attorney petitioned, the application of the case law set out in its previous judgments of November 13 2019 and November 14 2019 (regarding US mutual funds) should depend on whether the non-resident investors could provide evidence that it had not offset the excess tax borne in Spain through a foreign earned income tax credit taken in its country of residence.