Spain has issued official bulletins paving the way for the implementation of two new double tax agreements (DTA), with Georgia and Kazakhstan.
The treaty with Georgia had been signed on June 7, 2010, and was gazetted on June 1, 2011. Dividend withholding tax is capped at 10%, except in a case where the beneficial owner is a company (other than a partnership) holding directly at least a 10% stake in the paying company, when no tax will be charged. Royalties and interest arising in one state and beneficially owned by a resident of a contracting state will be taxable only in that other state.
Spain's DTA with Kazakhstan was signed on July 2, 2009 and gazetted on June 3, 2011.
Dividend withholding tax is to be charged at 5% where the beneficial owner is a company holding at least 10% of the capital of the paying company, and at 15% in all other cases.
Interest withholding tax will be levied at a maximum 10%, except in relation to the government, central bank, a political authority or subdivision of one of the states, 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 will be exempt. Royalties are to be taxed at a capped rate of 10%.
Both treaties provide permanent establishment, resident, immovable property rules, and allow for the exchange of information.
The treaty with Georgia had been signed on June 7, 2010, and was gazetted on June 1, 2011. Dividend withholding tax is capped at 10%, except in a case where the beneficial owner is a company (other than a partnership) holding directly at least a 10% stake in the paying company, when no tax will be charged. Royalties and interest arising in one state and beneficially owned by a resident of a contracting state will be taxable only in that other state.
Spain's DTA with Kazakhstan was signed on July 2, 2009 and gazetted on June 3, 2011.
Dividend withholding tax is to be charged at 5% where the beneficial owner is a company holding at least 10% of the capital of the paying company, and at 15% in all other cases.
Interest withholding tax will be levied at a maximum 10%, except in relation to the government, central bank, a political authority or subdivision of one of the states, 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 will be exempt. Royalties are to be taxed at a capped rate of 10%.
Both treaties provide permanent establishment, resident, immovable property rules, and allow for the exchange of information.
