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V1159-18 ·8 May 2018 ·consulta-vinculante Medium impact
FISCAL

No retention on Malta interest payments if treaty limits met

A Spanish company asks whether taxes should be withheld on interest from a loan from its sole shareholder in Malta. The DGT responds that, under the Spain-Malta double taxation treaty, interest is taxable only in Malta and exempt in Spain, provided it does not exceed market value.

In 6 key points

Lifecycle

2018-05-08PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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