- #
- 1
Spain: An attractive country for investment
- 2
Setting up a business in Spain
- 3
Tax System
- 4
Investment aid and incentives in Spain
- 5
Labor and social security regulations
- 6
Intellectual property law
- 7
Legal framework and tax implications of e-commerce in Spain
-
Downloads
- AI
Company and Commercial Law
- AII
The Spanish financial system
- AIII
Accounting and audit issues

- Introduction
- Central government taxes
- Corporate Income Tax
- Personal Income Tax
- Nonresident Income Tax
- Wealth Tax
- Inheritance and Gift Tax
- Spanish Value Added Tax
- Transfer and Stamp Tax
- Excise and Special Taxes
- Custom Duties on Imports
- Tax on Insurance Premiums
- Tax on Financial Transactions
- Tax on certain Digital Services
- Reporting obligations relating to Assets and Rights Abroad
- Tax on fluorinated greenhouse gases
- Excise tax on non-reusable plastic packaging
- Tax on waste sent to landfill, incineration and co-incineration
- Temporary taxes introduced by Law 38/2022 of December 27, 2022
- Special regime for startups
- Special Regimes of certain Autonomous Communities
- Local taxes
- Exhibit I - Corporate income tax incentives for investment
- Exhibit II - Treaty tax rates
- Exhibit III - Practical examples
- Exhibit IV - Case of Application of the Regime for foreign-securities holding companies (ETVE)...
- Exhibit V - Nonresident case study: Income obtained without a permanent establishment
- Exhibit VI - VAT case study
Exhibit II Treaty tax rates55
Type of IncomeRecipient Company's Country of Residence | Dividends (%) | Interest (%) | Royalties (%) |
---|---|---|---|
Albania | 0, 5 or 10 | 6 or 0 | 0 |
Germany | 15 or 10 | 0 | 0 |
Andorra | 5 or 15 | 0 or 5 | 5 |
Saudi Arabia | 5 or 0 | 5 or 0 | 8 |
Argelia | 15 or 5 | 5 or 0 | 14 or 7 |
Argentina 56 | 15 or 10 | 12 or 0 | 3, 5, 10 or 15 |
Armenia | 10 or 0 | 5 | 5 or 10 |
Australia | 15 | 10 | 10 |
Austria | 15 | 10 | 10 |
Azerbaijan | 10 or 5 | 0 or 8 | 5 or 10 |
Barbados | 0 or 5 | 0 | 0 |
Belgium (**) | 15 or 0 | 10 or 0 | 5 |
Belarus | 5 or 10 | 0 or 5 | 5 or 0 |
Bolivia | 15 or 10 | 15 or 0 | 15 or 0 |
Bosnia and Herzegovina | 10 or 5 | 7 or 0 | 7 |
Brazil | 10 or 15 | 15, 10 or 0 | 15 or 10 |
Bulgaria | 15 or 5 | 0 | 0 |
Cape Verde | 10 or 0 | 0 or 5 | 5 |
Canada | 5 or 15 | 0 or 10 | 10 or 0 |
Qatar | 0 or 5 | 0 | 0 |
Chile | 10 or 5 | 4, 5, 10 or 15 | 2, 5 or 10 |
Cyprus57 | 5 or 0 | 0 | 0 |
China | 10 or 5 | 10 | 10 |
China (Hong Kong) | 0 or 10 | 0 or 5 | 5 |
Colombia | 0 or 5 | 5 or 10 | 10 |
South Korea | 10 or 15 | 10 or 0 | 10 |
Costa Rica | 12 or 5 | 5 or 10 | 10 |
Croatia | 15 or 0 | 058 | 0 |
Cuba | 15 or 5 | 10 or 0 | 5 or 0 |
Denmark59 | 15 or 0 | 10 | 6 |
Ecuador | 15 | 0, 5 or 10 | 10 or 5 |
Egypt | 12 or 9 | 10 or 0 | 12 |
El Salvador | 12 or 0 | 0 or 10 | 10 |
United Arab Emirates | 5 or 15 | 0 | 0 |
Slovakia | 15 or 5 | 0 | 5 or 0 |
Slovenia | 15 or 5 | 5 or 0 | 5 |
United States | 0, 5 or 15 | 0 | 0 |
Estonia | 15 or 5 | 10 or 0 | 0, 5 or 10 |
Philippines | 15 or 10 | 0 or 15 or 10 | 15 or 20 |
Finland | 0, 5 or 15 | 0 | 0 |
France | 15 or 0 | 10 or 0 | 5 or 0 |
Georgia | 0 or 10 | 0 | 0 |
Greece | 10 or 5 | 8 or 0 | 6 |
Hungary | 15 or 5 | 0 | 0 |
India | 15 | 15 or 0 | 10 or 20 |
Indonesia | 15 or 10 | 10 or 0 | 10 |
Iran | 10 or 5 | 7.5 or 0 | 5 |
Ireland | 15 or 0 | 0 | 5, 8 or 10 |
Iceland | 15 or 5 | 0 or 5 | 5 |
Israel | 10 | 10 or 5 | 7 or 5 |
Italy | 15 | 12 or 0 | 8 or 4 |
Jamaica | 10 or 5 | 0 or 10 | 10 |
Japan | 10.5 or 0 | 0 or 10 | 0 |
Kazakhstan | 5 or 15 | 10 | 10 |
Kyrgyzstan | 18 | 0 | 0 ó 5 |
Kuwait | 5 or 0 | 0 or 10 | 5 |
Latvia | 10 or 5 | 0, 5 or 10 | 0, 5 or 10 |
Lithuania | 15 or 5 | 10 or 0 | 0, 5 or 10 |
Luxembourg | 15 or 10 | 10 or 0 | 10 |
North Macedonia | 15 or 5 | 5 or 0 | 5 |
Malaysia | 5 or 0 | 10 or 0 | 7 or 5 |
Malta | 5 or 0 | 0 | 0 |
Morocco | 15 or 10 | 10 | 10 or 5 |
Mexico | 10 or 0 | 4, 9 or 10 | 0 or 10 |
Moldova | 0, 5 or 10 | 0 or 5 | 8 |
Nigeria | 10 or 7.5 | 0 or 7.5 | 3.75 or 7.5 |
Norway | 15 or 10 | 10 or 0 | 5 |
New Zealand | 15 | 0 or 10 | 10 |
The Netherlands | 15, 10 or 5 | 10 | 6 |
Pakistan | 5, 7.5 or 10 | 10 | 7.5 |
Panama | 0, 5 or 10 | 5 or 0 | 5 |
Poland | 15 or 5 | 0 | 10 or 0 |
Portugal | 15 or 10 | 15 | 5 |
United Kingdom | 15, 10 or 0 | 0 | 0 |
Czech Republic | 15 ó 5 | 0 | 5 ó 0 |
Dominican Republic | 10 or 0 | 10 or 0 | 10 |
Romania | 0 or 5 | 0 or 3 | 3 |
Russia | 15 or 10 or 5 | 5 or 0 | 5 |
Senegal | 10 | 10 or 0 | 10 |
Serbia | 10 or 5 | 10 or 0 | 10 or 5 |
Singapore | 0 or 5 | 5 or 0 | 5 |
South Africa | 15 or 5 | 5 or 0 | 5 |
Sweden | 15 or 10 | 0 or 15 | 10 |
Switzerland60 | 15 or 0 | 0 | 0 or 5 |
Oman | 10 or 0 | 5 or 0 | 8 |
Thailand | 10 | 0 or 15 or 10 | 5, 8 or 15 |
Tajikistan | 18 | 0 | 0 or 5 |
Trinidad and Tobago | 0, 5 or 10 | 8 or 0 | 5 |
Tunisia | 15 or 5 | 10 or 5 | 10 |
Turkmenistan | 18 | 0 | 0 or 5 |
Turkey | 15 or 5 | 15 or 10 | 10 |
Ukraine | 18 | 0 | 0 ó 5 |
Uruguay | 5 or 0 | 10 or 0 | 5 or 10 |
Uzbekistan | 0, 5 or 10 | 5 or 0 | 5 |
Venezuela | 10 ó 0 | 10, 4.95 or 5 | 5 |
Vietnam | 15, 10, 7 or 5 | 10 | 10 or 5 |
55 The tax rates established in each treaty are indicated. The applicability of one or another depends, in each case, on the specific requirements established in the relevant treaty. Also to be considered are the provisions of the Multilateral Instrument, where it is applicable. Further information is available at: Normativa%20y%20doctrina/Normativa/CDI/Paginas/CDI.aspx
56 The previous tax treaty between Spain and Argentina, which came into force on July 28, 1994, was denounced unilaterally by Argentina and ceased to have effect on January 1, 2013. However, the new tax treaty, signed on March 11, 2013, stipulates that it is effective as from January 1, 2013 (meaning that, for practical purposes, there is no period not covered by a treaty).
57 Published on May 26, 2014, its date of entry into force being May 28, 2014.
58The agreement indicates that the rate applicable to Interest and Royalties is 8%. However, the protocol indicates that, after a period of 5 years from the entry into force of the Convention, the rates relating to interest and royalties (Articles 11 and 12 of the Convention) will be 0%. Since it entered into force on 20 April 2006, the deadline has already elapsed, so 0% applies.
59Denmark decided to terminate the Treaty with Spain as of January 1, 2009.
60 The new Protocol amending the Spain-Switzerland tax treaty has been signed and establishes the following rates:
-
- Dividends: 15 or 0.
- Interest: 0.
- Royalties: 0.