United States–Spain Treaties in ForceConvention for the Avoidance of Double Taxation • April 19th, 2017
Contract Type FiledApril 19th, 2017Annotation: The first income tax treaty between United States and Spain and the accompanying Protocol were signed on February 22, 1990. According to the Agreement, dividends, interest, and royalties paid by a resident of one State to a resident of the other Contracting State may be taxed by both States. A limit is placed, however, on the tax rate levied by the home State of the paying company. Thus, the maximum tax rate on dividends is 15%, with a lower rate of 10% pertaining to dividends received by a company which has at least a 25% stake in the paying company. A maximum tax rate on interest is similarly set by the home State of the paying company at 10%. Exemptions are allowed for interest received by one of the States of certain public sector instrumentalities thereof, interest on five-year or longer maturity loans by financial institutions, and interest paid in conjunction with the sale on credit of any industrial, commercial, or scientific equipment. The maximum tax rate on royal