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A Spanish company asks whether payments to a Dutch entity for a video on demand (VOD) service incorporated into its commercial offer should be classified as royalties. The DGT concludes that since the Spanish company does not acquire intellectual property rights, the payment does not constitute a royalty.
Cuestión planteada
La parte del pago por el servicio de video bajo demanda no es canon porque la consultante no adquiere derechos de reproducción, distribución, transformación ni comunicación pública de los contenidos. La titularidad de los derechos de propiedad intelectual permanece en la entidad neerlandesa, que es quien realiza la comunicación pública. Por tanto, la renta no encaja en la definición de cánones del Convenio de doble imposición.
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