María Delso

María advises Spanish and multinational companies on a wide range of VAT and indirect tax matters, including VAT planning, supply chain structuring, reorganizations and cross border transactions. She provides day to day guidance on compliance issues, tax ruling requests and the application of key VAT mechanisms, real time reporting obligations (SII) and refund procedures. Her practice also includes assisting clients in audits, voluntary disclosure processes and contentious matters involving complex interpretative questions under Spanish VAT law and EU principles.

She supports clients across sectors such as e-commerce, streaming services, pharmaceuticals, financial services and insurance, advising on the VAT treatment of complex supplies, branch–head office interactions and matters brought before the European Commission. In addition to her client work, María contributes to the Firm’s thought leadership through publications on EU VAT developments and she teaches indirect taxation in the digital economy at IE University.

• Advised a global leader in the software industry on the Spanish tax implications derived from the carve-out of one of its business lines to a third-party.
• Advised on a VAT dispute regarding damage related charges in the rental sector, currently before the Spanish Supreme Court with expected market wide impact.
• Advised financial institutions in new VAT audits and represented two entities before the National Court on a matter valued at USD 60 million.
• Advised on a VAT/IGIC audit in the Canary Islands and the subsequent appeal—the first case in the sector under the new legislative framework, expected to influence future criteria.
• Advised on a VAT dispute before the Spanish National Court concerning deductibility of promotional and marketing related services supplied through a major sports entity.
• Advised on cassation proceedings challenging the retroactive application of Spain’s amended “use and enjoyment” VAT rule, with arguments grounded in EU VAT law.
• Advised on a strategic permanent establishment (PE) assessment in Spain, covering VAT and corporate tax implications across multiple business units.
• Advised on a EUR 25 million withholding tax refund process relating to the qualification of payments for digital content distribution services.
• Advised on the recovery of an EUR 800,000+ surcharge improperly imposed under the EU MOSS regime due to a payment processing delay.
• Advised on the design of a VAT pro rata methodology for a financial institution in the Gulf region, to be formally presented to local tax authorities.
• Advised three group entities in ongoing Spanish tax audits while coordinating VAT strategy at EU level to ensure consistency and risk alignment.

• Madrid Bar Association