Norway and Spain: New Double Taxation Conventions signed in London on 14 March 2013
New comprehensive Double Taxation Conventions with Norway and Spain
were signed on 14 March by David Gauke, Exchequer Secretary to the
Treasury, and Kim Traavik, Ambassador of the Kingdom of Norway and
His Excellency Mr Federico Trillo-Figueroa Martínez-Conde of Spain
Important new features include:
- A zero withholding tax on dividends received by pension funds and
by companies that have a 10% or more control of the paying company.
- The latest OECD provisions on business profits, exchange of information,
assistance in collection and arbitration.
- A change to the pensions article so that pensions will be taxed at
source. Existing pensioners have the safeguard of being able to
elect to continue to be taxed in their state of residence as provided
by the current treaty.
- This new treaty has substantial benefits for companies, pension schemes
and individuals. The dividend withholding tax rate in the existing
treaty is 15% for portfolio investors and this will be reduced to 10%
for portfolio investors and to zero for direct investors and pension
schemes. The withholding tax rates for interest and royalties are also
reduced to zero.
- The new DTC also makes other welcome improvements, such as a provision
to clarify access to treaty benefits by participants in fiscally transparent
entities, an arbitration provision and updated anti-abuse measures.
Follow the link below to see the texts of the new Conventions which
will be published by the Stationery Office once presented to Parliament
Go to Tax treaties
signed/not in force
The Conventions will enter into force once the necessary legislative procedures
have been completed.