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V3282-20 ·4 November 2020 ·consulta-vinculante Medium impact
Tax

Voluntary submission of form 189 to avoid form 720 not feasible

A Portuguese investment firm asks whether it is obliged to submit form 189 and whether it can do so voluntarily to prevent clients from submitting form 720. The DGT states that the reporting obligation depends on whether the entity acts as a depositary or distributor, and that voluntary submission is not possible.

In 6 key points

How it affects those involved

Firms must determine their role as depositary or distributor to assess reporting obligations; voluntary submission of form 189 to avoid form 720 is not allowed.

Lifecycle

2020-11-04PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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