Annex I. Countries with agreements

Notes to the tables:

⁽¹⁾ This Convention is modified in its articles 2, 3, 11 and 24 by the Protocol signed on 24-02-1995, published in the BOE on October 2, 1995. ^(Back)

⁽²⁾ Modified by exchange of notes of 18 and 24 August 1970 (BOE of 2 February 1974); of February 22, 1973 (BOE of April 24, 1974) and of April 27, 1990 (BOE of July 28, 1992). ^(Back)

⁽³⁾ Not applicable to the Wealth Tax. ^{(back-Ireland) (back-Malta) (back-USA) (back-Korea) (back-Philippines) (back-Vietnam) (back-Australia)}

⁽⁴⁾ Modified by exchange of notes of 13-12-1993 and 17-06-1994 (BOE of 25 May 1995). ^(Back)

⁽⁵⁾ Initially applicable to Ukraine, Belarus, Moldova, Georgia, Armenia, Azerbaijan, Kazakhstan, Turkmenistan, Uzbekistan, Tajikistan and Kyrgyzstan.

By Exchange of Notes between Spain and the countries indicated below, the Convention for the avoidance of double taxation between Spain and the USSR , dated March 1, 1985, ceases to be in force from the dates indicated below:

COUNTRY	DATE	Official State Gazette
Armenia	10-10-2007	23-06-2010
Azerbaijan	28-01-2008	23-06-2010
Georgia	10-10-2007	23-06-2010
Moldova	01-10-2007	23-06-2010
Kazakhstan	08-07-2008	23-06-2010
Uzbekistan	21-07-2010	11-10-2010

Pursuant to the Agreement on the avoidance of double taxation between Spain and Belarus of 14 June 2017, the Agreement on the avoidance of double taxation between Spain and the USSR will no longer apply to Belarus as of 9 May 2021.

By Verbal Note of February 9, 1999 (BOE 08-10-2021) Turkmenistan reported the denunciation of the Convention to avoid double taxation between Spain and the USSR indicating that it would lose its validity on January 1, 2000.^(Back)

By Verbal Note of September 1, 2021 (BOE 02-07-2024) Kyrgyzstan reported the termination of the Convention to avoid double taxation between Spain and the USSR, indicating that it would lose its validity on January 1, 2023.^(Back)

⁽⁶⁾This agreement has been modified in its articles 2, 3, 9, 10, 14, 17, 19, 22, 24 and 25 and article 29 has been deleted by the Protocol signed on 17-03-1999, published in the BOE on 17-05-2000. ^(Back)

⁽⁷⁾The provisions apply from 01-01-2001 and from this date the agreement signed on 25-04-1963 will cease to apply. ^(Back)

⁽⁸⁾Modified by Exchange of notes of 09-11-1999 and 30-12-1999 (BOE 10-01-2001). ^(Back)

⁽⁹⁾See Resolution of 22-09-2003 (BOE 02-10-2003) on the interpretation of different points of said Convention. ^(Back)

⁽¹⁰⁾Its provisions apply from 01-01-2004 (Additional Act of 22 June 2000 amending the Convention and the Protocol of 14 June 1995) and from this date the Convention signed on 24-09-1970 will cease to apply. ^(Back)

^(eleven)As of May 1, 2004, these countries join the European Union (EU). ^{(back-Czech-Republic) (back-Slovakia) (back-Slovenia) (back-Estonia) (back-Hungary) (back-Latvia) (back-Lithuania) (back-Malta) (back-Poland)}

⁽¹²⁾ Member state of the EU since January 1, 2007. ^{(back-Bulgaria) (back-Romania)}

⁽¹³⁾ The provisions apply from 01-01-2007. EU Member State as of July 1, 2013. ^{(back-Croatia) (back-Egypt)}

⁽¹⁴⁾ This Agreement is amended by Protocols of June 29, 2006 (BOE 27-03-2007) and July 27, 2011 (BOE 11-06-2013). ^(Back)

^(fifteen) This Convention and its amending Protocol have been denounced by Verbal Note dated June 10, 2008 from the Danish Embassy (BOE 19-11-2008). As a result, the Convention and its amending Protocol cease to apply on 1 January 2009. ^(Back)

⁽¹⁶⁾ Modified by Protocol of 10-11-2009 (BOE 31-05-2010), enters into force on 16-07-2010. ^(Back)

⁽¹⁷⁾ Its provisions apply from 01-01-2010. ^(Back)

⁽¹⁸⁾ See Friendly Agreement Regarding the Treatment of Limited Liability Companies ( LLC ), US S Corporations (S Corporations) y otras entidades mercantiles consideradas sociedades de personas (partnerships) or entities not subject to US corporate tax (BOE 13-08-2009). ^(Back)

⁽¹⁹⁾ Correction of errors (BOE 26-05-2011). ^{(back-Albania) (back-Georgia)}

^(twenty) Applicable to East Timor. ^(Back)

^(twenty-one) Its provisions apply from 01-01-2013. ^(Back)

⁽²²⁾ On June 29, 2012, Argentina denounced the Convention to avoid double taxation. Pursuant to this denunciation and in accordance with the provisions of Article 29 of the Convention, the Convention shall cease to have effect as of 1 January 2013. ^(Back)

⁽²³⁾ Its provisions apply from 01-01-2013. ^(Back)

⁽²⁴⁾ Its provisions apply from 12 June 2014. ^(Back)

⁽²⁵⁾ This agreement is modified by the Protocol signed on November 18, 2014 (BOE 08-10-2015). ^(Back)

⁽²⁶⁾ Exchange of interpretative letters of the Convention (BOE 15-07-2016). ^(Back)

⁽²⁷⁾ Modified by Protocol of 17 December 2015 (BOE 07-07-2017). ^(Back)

⁽²⁸⁾ Modified by Protocols of December 2, 2009 (BOE 05-23-2018) and April 15, 2014 (BOE 08-02-2018). ^(Back)

⁽²⁹⁾ Its provisions apply from 1 January 2019. ^(Back)

⁽³⁰⁾ Modified by Protocol of January 14, 2013 (BOE 10-23-2019). ^(Back)

⁽³¹⁾ Modified by Protocol of October 26, 2012 (BOE 07-09-2020). ^(Back)

⁽³²⁾ Its provisions apply from 2022. ^(Back)

⁽³³⁾ Its provisions apply from 7 January 2021. ^(Back)

^{(3. 4)} Its provisions apply from 2022. ^(Back)

⁽³⁵⁾ Its provisions apply from 1 January 2022. ^(Back)

⁽³⁶⁾ Its provisions apply from May 9, 2021. ^(Back)

⁽³⁷⁾ Its provisions apply from 2 May 2021. ^(Back)