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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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La UK LLP, al no estar sujeta a imposición en UK, no puede invocarel CDI ES-UK. El art. 4.4 CDI ES-UK tampoco aplica al no ser la consultante residente en UK. El CDI ES-Singapur permite a España gravar los intereses al máximo del 5% si la consultante es beneficiaria efectiva (art. 11.2), sin perjuicio del Protocolo del convenio y del art. 7.1 IML. La exención del art. 11.3.f) requiere acuerdo de autoridades competentes no alcanzado en la fecha de la consulta; la del art. 11.3.g) exige probar ser el Government of Singapore Investment Corporation, hecho no acreditado.
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