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Eduardo Gómez de Salazar The "Beckham clause" has been offered as an incentive for attracting talent in the Spanish Personal Income Tax Law since 2004. It involves a special tax system available for executives and other employees who, on being sent to Spain, meet the requirements to be treated as Spanish tax residents on the terms described in Article 9 of the Personal Income Tax Law, and satisfy the following conditions: They must not have been resident in Spain in the 10 years preceding their assignment to Spain; Their assignment to Spain must take place as a result of an employment contract; Their work must actually be performed in Spain; That work must be performed for a Spanish resident company or entity; The salary income earned under that employment relationship must not be exempt from personal income tax; and The expected compensation under the employment contract in each of the tax periods in which this special system is applied cannot exceed €600,000 ($766,000) per annum. This system allows any taxpayers becoming tax resident in Spain to elect to be taxed, for the five fiscal years following the year they became tax resident, to apply the rules on determining the tax debt established in the Spanish law for non-tax residents.

Jacques Kistler

Jim Fuller

Sean Foley

The latest international updates from our correspondents around the world.

Over the years, Singapore has been taking active steps to position itself as an intellectual property (IP) hub in Asia. Harvey Koenig, tax partner at KPMG in Singapore, explores how, in this innovation-driven globalised economy, IP has become an important driver of growth.

In the past three years, the eyes of the global public have been drawn to the normally quiet world of international taxation by corporations structuring their businesses in a way that is perceived to be for no other purpose than the avoidance of paying tax. In this light, Salman Bin Hassan Al-Thani, chief financial officer and director of tax at the Qatar Financial Centre Authority, analyses the transfer pricing regimes across the Gulf Cooperation Council (GCC).

Nancy Manzano and David Deputy, of Vertex, argue that today’s tax executives must have skills that include having confidence in using the technology required to manage their company’s tax affairs effectively.

Bob van der Made At the beginning of 2014, the European Commission announced a new focus on EU fiscal state aid. This was triggered by the unfolding OECD/G20s Base Erosion and Profit Shifting (BEPS) Action Plan and must also be seen in the context of the EU's own agenda to crack down on aggressive tax planning, tax avoidance and tax evasion by multinational companies. In concrete terms, this has resulted in the opening of a series of investigations into specific tax rulings and tax regimes. These cases have attracted a considerable amount of attention from the Commission. On specific tax rulings, the Commission took three decisions to launch formal investigations in this new context on June 11 2014, with regard to alleged aid to Apple in Ireland, alleged aid to FFT (allegedly Fiat Finance and Trade) in Luxembourg, and alleged aid to Starbucks in The Netherlands. On October 7 2014, the Commission announced a fourth in-depth investigation, namely with respect to alleged aid to Amazon in Luxembourg.

Ricardo Rendon and Eduardo Valenzuela, partners at Chevez Ruiz Zamarripa, analyse the latest developments regarding taxation of the oil & gas sector as part of the Mexican energy reforms.