Tax Newsletter - December 2025 - January 2026
Spain -
If an EU-resident recipient of a royalty is not its beneficial owner, the reduced withholding rate under the tax treaty cannot be applied either
According to the Supreme Court, if the payments fall within the scope of the Royalty Directive and the exemption does not apply because the recipient is not the “beneficial owner”, the withholding must be made by applying the rate of the domestic legislation and not that of the relevant tax treaty.
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