New Treaties and Treaty Changes
1. New Double Taxation Agreement Between Spain and Japan:
The new Double Taxation Treaty (DTT) was signed between Spain and Japan on 26th February 2021. The provisions of the new DTT, published in the Spanish Official Gazette (BOE), entered into force on 1st January 2022.
Interest Payments
According to Article 11 of the treaty, a resident in Japan will, from 1st January 2022 onwards, have the right not to be withheld in Spain with more than 0% on interest payments.
Dividend Distributions
According to Article 10 of the treaty, a resident in Japan will, from 1st January 2022 onwards, have the right not to be withheld in Spain with more than 5% in case of dividends distributed by Spanish companies, except for the following cases:
0% in case the beneficial owner, with residence in Japan, is an entity that directly or indirectly owns shares representing at least 10% of the voting rights of the Spanish company distributing the dividend and such shareholder has held the shares in the distributing company for a minimum period of 12 months including the dividend payment date
0% if the beneficial owner, with residence in Japan, is a pension fund.
2. New Double Taxation Agreement Between Spain and Azerbaijan:
Interest Payments
According to Article 11 of the treaty, from 1st January 2022 onwards, if the beneficial owner, with residence in Azerbaijan, is the State, the Central Bank, a political subdivision, a local authority, or a statutory body, they will be tax exempt. The remainder of the residents in Azerbaijan will have the right not to be withheld in Spain with more than 8%.
Dividend Distributions
According to Article 10, from 1st January 2022 onwards, a resident in Azerbaijan will have the right not to be withheld in Spain with more than 10% in case of dividends distributed by Spanish companies.
3. New Double Taxation Agreement Between Spain and Romania:
Interest Payments
According to Article 11, from 14th January 2022 onwards, if the beneficial owner, with residence in Romania, is the State, the Central Bank, a political subdivision, a local authority, or a statutory body, they will be tax exempt. The remainder of the residents in Romania will have the right not to be withheld in Spain with more than 3%.
Dividend Distributions
According to Article 10, from 14th January 2022 onwards, if the beneficial owner, with residence in Romania, is a pension scheme, then it will be tax exempted. The remainder of the residents in Romania will have the right not to be withheld in Spain with more than 5%.