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V1825-24 ·31 July 2024 ·consulta-vinculante Medium impact
Tax

UK LLP classified as ERAR; 5% IRNR on Singapore interests under ES-Singapore CDI

A Singapore entity fully owned by the Singapore Ministry of Finance holds 100% of a UK LLP. The DGT classifies the UK LLP as an entity of rental attribution (ERAR), excluding it from UK residency for CDI ES-UK and Article 4.4 of the treaty. The ES-Singapore CDI applies to the Singapore entity, with a maximum 5% IRNR retained in Spain on interest paid by resident debtors, unless Article 11.3 exemptions apply, which the DGT considers unestablished.

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2024-07-31PublishedPublished 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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