Annex III. Limits of taxation in conventions

Notes to the table

⁽¹⁾ See article 10 of the Agreement.^{(Go back)}

⁽²⁾ See article 10 of the Agreement.^{(Go back)}

⁽³⁾ See article 12 of the Agreement.^{(Go back)}

⁽⁴⁾ The exemption for parent-subsidiary dividends and interest is applicable to income accrued since 01-06-2007.^{(Go back)}

⁽⁵⁾ The exemption for royalties between associated companies is applicable to income accrued since 02-07-2011.^{(Go back)}

⁽⁶⁾ The Danish-Spanish Convention and its Protocol has been denounced by Denmark (BOE 19-11-2008).Consequently, the agreement and the protocol modifying it ceased to be in force on 1 January 2009.^(Return)

⁽⁷⁾ Articles 11 and 12 see Protocol:after a period of 5 years from the coming into force of the agreement the rates will be 0%.^{(Go back)}

⁽⁸⁾ See article 10 of the Agreement.^{(Go back)}

⁽⁹⁾ See article 10 of the Agreement.^{(Go back)}

⁽¹⁰⁾ The Protocol amending the Convention of 27 June 2011 (BOE 11-06-2013) modifies the minimum shareholding percentage (which is now 10%) and introduces an exemption (dividends paid to a recognised pension fund or plan) ^(Back)

⁽¹¹⁾ The Protocol amending the Convention of 23 November 1976 (BOE 08-10-2015), applicable to dividends accrued since 12-12-2015, introduces a case of exemption (dividends paid to a pension plan or retirement plan) and establishes a taxation limit of 5% for parent-subsidiary dividends provided that the minimum percentage shareholding is at least 10%.^{(Go back)}

⁽¹²⁾ The Protocol amending the Convention of 23 November 1976 (BOE 08-10-2015), applicable to interest accrued since 12-12-2015, modifies the taxation limit (from 15% to 10%) and introduces a case of exemption (loans made or credits assigned by the Canadian Export Credit Agency).^{(Go back)}

⁽¹³⁾ See article 10 of the Agreement.^{(Go back)}

⁽¹⁴⁾ See article 28 of the Agreement.^{(Go back)}