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Spain - Treaty Interpretation and Treaty Override: The Spanish Case Law on Royalties under the Spain-United States Income Tax Treaty (1990)

Country:
Spain
Author:
R. Bernales Soriano
Issue:
European Taxation, 2013 (Volume 53), No 9/Special Issue
Published:
8 August 2013
The author, in this article, summarizes the position of the Spanish tax authorities and courts on the interpretation of treaty terms under the pre-1995 version of article 3(2) of the OECD Model, in particular regarding the taxation of royalties, and discusses the possibility that such an interpretation constitutes treaty override.
 
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