The Spanish National Court decides the case of Sabic Innovative against the tax administration (Appeal 367/2010) as fraud of law.
The Court ruled that the intra-group debt transaction is usually tax-driven and did not have an economic or business rationale. It is an artificial transaction with the sole aim to reduce taxation in Spain. The facts perfectly matched the legal figure of fraud delay (fraud of law, a concept similar to the abuse of law) included in the Spanish legislation.
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