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A query is made as to whether contributions to the CJPB are covered by the Convention for the avoidance of double taxation between Spain and Uruguay. The DGT responds that, as the CJPB is a non-state public law entity, said contributions are not taxes and fall outside the scope of the convention.
Question posed
The Convention between Spain and Uruguay applies to Income Tax and Wealth Tax levied by the States, their political subdivisions or local entities. Given that the CJPB is a non-state public law entity, its contributions do not constitute a tax levied by the State or its subdivisions. Therefore, this pecuniary benefit is not included within the scope of application of the Convention.
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