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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Spain: Treaty summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Spain is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on

Portfolio dividends 10% (Note 1) Article 10
Dividends on direct investments 0% Article 10
Conditions for lower rate on dividends on direct investments The beneficial owner is a company which holds directly or indirectly at least 10 per cent of the capital in the company paying the dividends Article 10
Property income dividends 15% Article 10
Interest 0% Article 11
Royalties 0% Article 12
Government pensions Taxable only in Spain unless the individual is a resident of, and a national of, the UK Article 18
Other pensions Taxable only in the UK Article 17
Arbitration Yes Article 25


Note 1: Dividends beneficially owned by a pension scheme established in the UK are exempt from tax in Spain.