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A Spanish company inquired whether payments under a cloud software distribution contract with an Irish entity should be classified as royalties or business profits. The DGT determines that if the software is standard and does not allow for adaptation or reproduction, the payments are business profits.
Question raised a) Whether the payments to the Irish company are classified as business profits or as royalties, in application of the Spanish-Irish Convention for the avoidance of double taxation.
According to the Convention between Spain and Ireland, payments for the distribution of copies of computer programs are classified as business profits under Article 7 if they do not include the right to reproduce them. For this criterion to apply, the software must be standard, without the right of adaptation to the customer or reproduction, and must be identical in all countries where it is distributed. If these conditions are met, the income is only taxable in Ireland and there is no withholding obligation in Spain.
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