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A Spanish company asks how to classify compensatory payments to a Brazilian company under a cost-sharing agreement for developing a technological platform. The DGT examines whether such payments, intended to balance contributions and expected benefits, constitute business profits or royalties under the Spain-Brasil Convention.
Question raised: It is raised whether, in the event that SES has to make compensatory payments to SBR, such payments would be subject to tax in Spain, their classification and, where applicable, the applicable withholding tax rate.
Los pagos compensatorios en un ARC de desarrollo tienen por causa el reembolso de costes incurridos en exceso por un participante. La calificación depende de la naturaleza del pago: la parte que corresponde a la transmisión del intangible se trata como la transmisión de un elemento patrimonial, lo que podría ser un beneficio empresarial (artículo 7 del Convenio) o un canon (artículo 12 del Convenio) si se considera una concesión de uso de derechos. La parte que corresponde a gastos no activados se tratará según las reglas generales de la legislación nacional.
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