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Spain Publishes Synthesized Text of Tax Treaty with South Africa as Impacted by BEPS MLI — Orbitax Tax News & Alerts

Spain's Ministry of Finance has published the synthesized text of the tax treaty with South Africa as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized text was prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaties and the MLI take precedence and remain the legal texts applicable.

The MLI applies for the 2006 Spain-South Africa tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2024; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2024.

Click the following link for the tax treaty page on the Ministry of Finance website, which includes the synthesized texts of Spain's tax treaties.