Executive summary
The Spanish Supreme Court (Tribunal Supremo) issued a decision (case number 1996/2019) on 23 September 2020, confirming the most recent case law regarding the limits on the dynamic interpretation of tax treaties.
This decision is extremely relevant for the interpretation and application of tax treaties that have not been amended in line with the latest versions of the Organisation for Economic Co-operation and Development (OECD) Model Tax Convention (OECD MTC). In addition, …