Treaty Update: Armenia - Spain

19/4/2012

The DTA signed between Armenia and Spain on December 16, 2011, entered into force on March 21, 2012.

Treaty Update: Hong Kong - Spain

13/3/2012

According to information supplied by the Hong Kong Inland Revenue Department, the DTA signed between Spain and Hong Kong will enter into force on April 16, 2012.

Treaty Update: Spain - Hong Kong

20/1/2012

The Spanish Chamber of Commerce in Hong Kong confirmed on January 16, 2012, that Hong Kong has concluded its ratification procedures for the entry into force of the Hong Kong-Spain DTA from April 16, 2012.

Treaty Update: Dominican Republic - Spain

21/11/2011

According to preliminary media reports, Spain and the Dominican Republic signed a DTA on November 16, 2011, in Madrid.

Treaty Update: Spain - Dominican Republic

9/11/2011

According to preliminary media reports, the government of Spain on November 4, 2011, approved for signature a DTA with the Dominican Republic.

Treaty Update: Singapore - Spain

2/11/2011

The Singapore Tax Authority confirmed on November 1, 2011, that the DTA between Singapore and Spain signed on April 13, 2011, will enter into force on February 1, 2012.

Treaty Update: Armenia - Spain

19/10/2011

According to preliminary media reports, the pending DTA between Armenia and Spain, signed in December 2010, was ratified by Armenia on October 3, 2011. This follows the completion of ratification procedures by Spain in May 2011.

Treaty Update: Spain - Panama

5/10/2011

According to preliminary media reports, a TIEA between Panama and Spain was signed on September 26, 2011.

Treaty Update: Spain - Hong Kong

27/9/2011

According to preliminary media reports, the DTA between Spain and Hong Kong was ratified by the Spanish Congress on September 15. The DTA follows the OECD model and includes provisions for the exchange of information.

Treaty Update: Spain - Singapore

26/9/2011

According to preliminary media reports, the pending DTA and accompanying Protocol between Spain and Singapore was ratified by the Spanish Congress on September 15, 2011.

Treaty Update: Barbados - Spain

13/9/2011

According to the government of Barbados, the DTA between Barbados and Spain, signed on December 1, 2010, has been ratified and will enter into force on October 14, 2011.

Treaty Update: Barbados - Spain

24/8/2011

According to preliminary media reports, the DTA signed between Spain and Barbados on December 1, 2010, and ratified on May 25, 2011, is to enter into force on October 14, 2011.

Treaty Update: Spain - Kazakhstan

22/8/2011

According to preliminary media reports, the DTA between Spain and Kazakhstan entered into force on August 18, 2011. The DTA was signed on July 2, 2009.

Treaty Update: Switzerland - Spain

29/7/2011

Switzerland and Spain signed a protocol to their existing DTA on July 27, 2011. The Protocol reduces withholding tax on certain dividends and includes provisions on the exchange of information in line with international standards.

Treaty Update: Spain - Andorra

7/7/2011

According to media reports, Spanish President, José Zapatero said on July 4, 2011, that, following positive revisions to the Andorran tax regime, Spain is pursuing the signing of a Double Tax Agreement with Andorra.

Treaty Update: Panama - Spain

7/7/2011

According to media reports, the DTA between Panama and Spain will enter into force on July 25, 2011. The DTA was signed on October 7, 2010, and will amend dividend, interest and withholding tax rates.

Treaty Update: Azerbaijan - Spain

24/6/2011

According to an Azerbaijani government release, dated June 17, 2011, during a recent official visit to Spain, ministers expressed their readiness to sign a DTA.

Treaty Update: Spain - Armenia

13/6/2011

Spain ratified

Treaty Update: Spain - Kazakshstan

8/6/2011

The treaty was signed on July 2, 2009 and gazetted on June 3, 2011. In Kazakhstan, the DTA applies to corporate tax, income tax, tax on capital. In Spain, the DTA applies to income tax, corporate tax, income tax for non residents, wealth tax and local taxes on income and capital. It provides permanent establishment, resident, immovable property rules, and for the elimination of double taxation and the exchange of information. Dividend withholding tax is charged at 5% where the beneficial owner is a company holding at least 10% of the capital of the paying company, and at 5% in all other cases. Interest is taxed at 10%, except in the case of the state, central bank, political authority of one of the states, and interest paid by reason of a loan or credit due to that state or one of its central authorities or political subdivisions, or a public financial institution, when such interest is exempt. Royalties are taxed at 10%.

Treaty Update: Spain - Singapore

8/6/2011

Spain ratified

Treaty Update: Spain - Pakistan

8/6/2011

The DTA was signed on June 2, 2010, and was gazetted in Spain on May 16, 2011. In Spain, the DTA applies to income tax, corporation tax and income tax on non residents. In Pakistan, the DTA applies to income tax. The DTA provides permanent establishment, business profit, resident, immovable property rules, and for the elimination of double taxation and the exchange of information. Dividends are taxed at: 0% where the beneficial owner is a company (other than a partnership) holding directly at least 10% of the paying company; 10% in all other cases. Royalties and interest are exempt from withholding tax.

Treaty Update: Albania - Spain

8/6/2011

The TIEA been signed on July 2, 2010, and applies from May 4, 2011.

Treaty Update: Spain - Albania

8/6/2011

The DTA was signed on July 2, 2010. In Spain, it applies to income tax, corporation tax, income tax on non residents, and local income taxes. In Albania, it applies to income taxes, and the tax on small business activties. It provides permanent establishment, business profit, resident, immovable property rules, and for the elimination of double taxation and the exchange of information. Divdend withholding tax is charged at: 0% where the beneficial owner is a company (other than a partnership) holding directly at least a 75% state in the paying company; 5% where the beneficial owner is a company (other than a partnership) holding directly at least a 10% stake in the paying company; and 10% in all other cases. Interest withholding tax is charged at 6%, except in the case of one of the states, its central bank, or a political subdivision/public authority, interest paid by reason of a loan or credit due to that State or one of its central authorities, political subdivisions, or local credit agency for export, or granted, issued, guaranteed or insured by them, is a financial institution, interest paid on account of a debt arising as a result of the sale on credit of any equipment or materials, goods or services, or a pension fund approved by tax purposes by that state and is generally tax exempt in that state, when a 0% charge applies. Royalties are exempt.

Treaty Update: Spain - Hong Kong

3/6/2011

The DTA follows the OECD model and includes provisions for the exchange of information to the OECD standard. The DTA reduces the dividend withholding tax from 20% to 10%, except in the case of a company (other than a partnership) holding directly at least 25% of the capital of the paying company, when 0% will be charged. Spanish interest withholding tax will be reduced from 19% to 5%, and royalties tax from 24% to 5%. Branch Profits Tax on after-tax profits remitted by a Spanish permanent establishment to its foreign head office will cease to apply to Hong Kong residents. It also sets out shipping and airline tax rules. Under the agreement, Hong Kong will lose its tax haven status from the time of application.

Treaty Update: Spain - Barbados

3/6/2011

Spain ratified

Treaty Update: Spain - Georgia

3/6/2011

The treaty was signed on June 7, 2010, and was gazetted on June 1, 2011. The DTA will apply from January 1, 2012. In Georgia, the DTA applies to income tax, property tax. In Spain, the treaty applies to income tax, corporation tax, income tax on non-residents, wealth tax and local taxes on income and capital. It provides permanent establishment, resident, immovable property rules, and for the elimination of double taxation and the exchange of information. Dividend withholding tax is charged at: 0% where the beneficial owner is a company (other than a partnership) holding directly at least a 10% stake in the paying company; 10% in all other cases. Royalties and interest are exempt from withholding tax.

Treaty Update: Cayman Islands - Spain

3/6/2011

Spain will no longer classify the Cayman Islands as a tax haven under its domestic legislation. The date and location for the signing will be confirmed in the coming months.

Treaty Update: Singapore - Spain

2/6/2011

In Singapore, the DTA applies to income tax. In Spain, the DTA applies to income tax on individuals and non-residents, and corporation tax, and local taxes on income. Incorporates internationally agreed standards for the exchnage of tax information. The DTA also sets out permanent establishment, capital gains and business profits rules. Dividend withholding tax is charged at the following rates: 0% if the beneficial owner is a company (other than a partnership) holding directly at least 10% of the capital of the paying company; 5% in all other cases. In the case of distributions made out of real estate invetment trust: 5% if the beneficial owner of the distrubutions holds less than 10% of the value of the trust capital. Interest withholding tax is charged at 5, except in the case of the government, central bank or political authority of that state, or by a financial institution in one state paying the interest to a financial institution in the other, a pension fund approved for tax purposes whose income is generally exempt from tax, paid in respect of certain loans, or is the Government of Singapore Investment Corporation. Royalty withholding tax is limited to 5%.

Treaty Update: Germany - Spain

1/6/2011

The DTA replaces the 1966 treaty. Witholding tax on dividends paid from intergovernmental holdings is reduced from 10% to 5%. Social security pension provisions are also changed, given the paying state a limited right of atxation. For new retirees from 2015, the withholding tax rate is 5%, and for new retirees after 2030, it is 10%. It also provides for the exchange of information to the OECD standard.

Treaty Update: Spain - Bahamas

26/5/2011

Spain ratified. The TIEA was signed on March 11, 2010. In Spain, the TIEA covers individual income tax, corporation tax, non-resident income tax, capital tax, inheritance and gift tax, transfer tax, VAT, excise tax and local taxes on income and capital. In the Bahamas, the TIEA covers taxes of all kinds. The TIEA provides for the exchange of information relevant to the administration and enforcement of domestic tax laws, the determination, assessment and colection of taxes, the recovery and enforcement of tax claims, and the investigation/prosecution of tax matters. The TIEA also provides for the exchange of information held by banks and other financial institutions, and information regarding the ownership of companies, partnerships, trusts, foundations etc.

Treaty Update: Spain - Georgia

26/5/2011

Spain ratified

Treaty Update: Spain - Panama

26/5/2011

Spain ratified