A new Tax Treaty between Spain and Qatar has recently been published. This Tax Treaty is based on the OCDE model and the main implications are:
- Dividends paid out to a resident in the other state can only be trigger a 5 % withholding tax. However, if the recipient is a company who owns at least 10 % of the voting rights or share capital of the paying company, then the withholding tax will be cero.
- Likewise, interest and royalties paid to a resident in the other State can only be taxed in the country of residence of the tax payer, as long as the recipient is the beneficial owner
- Finally, gains derived by a resident of a State from the sale of shares deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other state may be taxed in the State where the property is located.