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A Spanish company is inquiring whether it should apply a 5% withholding tax on payments made for the use of a software application owned by a French company. The DGT indicates that if the application is not strictly standard and is used for professional purposes, such payments may be classified as royalties.
Question raised: Inquiry is made regarding the appropriateness of applying a 5% withholding tax on payments made to the French company.
Según el Convenio entre España y Francia, los cánones pueden tributar en España con un límite del 5% del importe bruto si el perceptor es el beneficiario efectivo. Dado que los derechos sobre programas informáticos no se consideran derechos de autor sobre obras literarias o artísticas, se aplica la limitación del 5% establecida en el Convenio. Por tanto, si la aplicación no es estándar, los pagos pueden ser objeto de tributación en España por el IRNR con dicho límite.
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