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A Swiss resident enquires about the tax implications of transferring funds from a Swiss to a Spanish account. The DGT states that the transfer of own funds does not constitute income, and under the Spain-Switzerland double taxation treaty, interest from the Spanish account is only taxable in Switzerland.
Question raised
The transfer of own funds from abroad has no tax implications as it does not constitute the acquisition of income. The interest generated by the bank account in Spain is subject to taxation exclusively in Switzerland pursuant to Article 11 of the Convention between Spain and Switzerland. Therefore, no withholding tax is applicable in Spain in accordance with Article 31.4.a) of the TRLIRNR.
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