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A Spanish entity inquired whether dividends paid to a Kuwait sovereign fund were exempt under the double taxation treaty. The DGT replied that exemption does not apply as the fund fails to meet the requirement of having its capital divided into shares or participations.
Dividends paid to Kuwait sovereign funds are subject to Spanish tax with a 5% cap, unless the fund meets specific capital structure requirements under the double taxation treaty.
The tax team reviews your specific situation.
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