Spain - Anti-abuse provisions

Spain

Anti-abuse provision: Extraterritorial Tax

Article 10-7:

Where a company which is a resident of one of the States derives profits or income from the other State, that other State may not impose any tax on the dividends paid by the company to persons who are not residents of that other State or subject the company's undistributed profits to a tax on undistributed profits. even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.