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V1219-14 ·7 May 2014 ·consulta-vinculante Medium impact
Tax

Payments for pre-installed ATM software may not be taxable in Spain if classified as business benefit

A company inquired whether payments to an Irish entity for pre-installed ATM software were subject to Spanish taxation. The DGT determines that, as the software is standard with no adaptation or reproduction rights, the payment qualifies as a business benefit and not as a royalty.

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2014-05-07PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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