DT17552 - Double Taxation Relief Manual: Guidance by country: Spain: Treaty summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ 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. The text of the treaty itself should be consulted for the full details. The 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	The 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.