Published online by Cambridge University Press: 05 November 2014
The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Spanish tax treaties
On 30 May 2010 Spain had tax treaties in force with seventy-six countries. Some of these are the result of the application of the tax treaties previously signed with Czechoslovakia (the Czech Republic and Slovakia), the former USSR (Azerbaijan, Belarus, Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, Ukraine and Uzbekistan) and Indonesia (Indonesia and Timor). Moreover, Spain has negotiated some other tax treaties, of which nine are awaiting signature (Albania, Armenia, Barbados, Georgia, Germany, Namibia, Pakistan, Panama and Syria) and the other eight are pending publication in the official journal of the signatory countries (Bosnia, Costa Rica, Kazakhstan, Kuwait, Nigeria, Peru, Senegal and Uruguay), which makes a total of ninety-one countries involved in the tax treaty process with Spain. Of the tax treaties previously signed, Denmark gave notice of termination of its tax treaty on 10 June 2008 and since 1 January 2009 it is no longer applicable.
Spain has tax treaties in force with all Member States of the EU (except Cyprus and Denmark), plus other European countries, such as Belarus, Croatia, Georgia, Iceland, Macedonia, Moldova, Norway, Russia, Serbia, Switzerland, Turkey and Ukraine. Its treaties in force with Asian countries include those with the Central Asian republics previously mentioned (Azerbaijan, Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan and Uzbekistan), China, India, Indonesia, Iran, Israel, Japan, Korea, the Philippines, Saudi Arabia, Thailand, Timor, United Arab Emirates and Vietnam. In the Americas Spain has treaties in force with Argentina, Bolivia, Brazil, Canada, Chile, Colombia, Cuba, Ecuador, El Salvador, Jamaica, Mexico, Trinidad and Tobago, the USA and Venezuela. In Africa Spain has treaties in force with countries including Algeria, Egypt, Morocco, South Africa and Tunisia, and Australia and New Zealand in Oceania.
To save this book to your Kindle, first ensure [email protected] is added to your Approved Personal Document E-mail List under your Personal Document Settings on the Manage Your Content and Devices page of your Amazon account. Then enter the ‘name’ part of your Kindle email address below. Find out more about saving to your Kindle.
Note you can select to save to either the @free.kindle.com or @kindle.com variations. ‘@free.kindle.com’ emails are free but can only be saved to your device when it is connected to wi-fi. ‘@kindle.com’ emails can be delivered even when you are not connected to wi-fi, but note that service fees apply.
Find out more about the Kindle Personal Document Service.
To save content items to your account, please confirm that you agree to abide by our usage policies. If this is the first time you use this feature, you will be asked to authorise Cambridge Core to connect with your account. Find out more about saving content to Dropbox.
To save content items to your account, please confirm that you agree to abide by our usage policies. If this is the first time you use this feature, you will be asked to authorise Cambridge Core to connect with your account. Find out more about saving content to Google Drive.