Share with your friends

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.


Related content

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

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal