Taxation of legal entities - Europa League

UEFA Europa League Final 2022, Legal Information

Content Type
UEFA Guidelines
English (United Kingdom)

The general corporate income tax rate in Spain is 25%.

Spanish resident companies are taxable in Spain on their worldwide income.

Non-resident companies are subject to a non-resident’s corporate income tax on trading profits attributable to a Spanish permanent establishment (PE), at a rate of 25%.

Corporate income tax payers and non-resident companies operating through a Spanish PE with net turnover above €1 million may also be subject to a local ‘business and professional services tax’, at locally determined rates.

Spain generally applies the definition of permanent establishment given in Article 5 of the OECD Model Tax Convention. To provide some indicative guidance, this would generally mean that activities of a preparatory or auxiliary nature linked to the staging of an event such as UELF 22 performed by a non-resident entity in Spain for a period of less than six months would not lead to the creation of a Spanish PE (though careful analysis of expected activities in Spain and the applicable double tax treaty should be performed by each UEFA partner).