DT17552 - Double Taxation Relief Manual: Guidance by country: Spain: Treaty summary
»Ê¹ÚÌåÓýapp table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. »Ê¹ÚÌåÓýapp rate shown is the ‘treaty rateâ€� and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. »Ê¹ÚÌåÓýapp ‘treaty rateâ€� is the maximum rate at which Spain is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. »Ê¹ÚÌåÓýapp text of the treaty itself should be consulted for the full details. »Ê¹ÚÌåÓýapp text of the treaty can be found on gov.uk .
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 10% (Note 1) | 10 |
| Dividends on direct investments | 0% | 10 |
| Conditions for lower rate on dividends on direct investments | »Ê¹ÚÌåÓýapp beneficial owner is a company which holds directly or indirectly at least 10% of the capital in the company paying the dividends | 10 |
| Property income dividends | 15% | 10 |
| Interest | 0% | 11 |
| Royalties | 0% | 12 |
| Government pensions | Taxable only in Spain unless the individual is a resident and national of the UK | 18 |
| Other pensions | Taxable only in the UK | 17 |
| Arbitration | Yes | 25 |
Note 1: Dividends beneficially owned by a pension scheme established in the UK are exempt from tax in Spain.