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Protocol to income tax treaty between United States and Spain, entry into force

Protocol to income tax treaty, United States and Spain

The U.S. Treasury Department today announced that a Protocol to the income tax treaty between the United States and Spain will enter into force on November 27, 2019.


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The Protocol amending the United States-Spain income tax treaty (1990) was signed in early 2013 and provides for: 

  • Exemption from withholding taxes for interest (subject to certain exceptions), royalties, and capital gains
  • Exemption from withholding tax for dividends paid to certain pension funds, or to companies holding shares representing 80% or more of voting power in the subsidiary and meeting certain other requirements (and a parallel exemption from branch profits tax)
  • A new comprehensive limitation on benefits (LOB) article
  • A new provision addressing income earned through fiscally transparent entities
  • Mandatory binding arbitration of unresolved competent authority cases
  • Broad exchange of information between competent authorities for tax purposes

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