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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.
Cuestión planteada
La transferencia de fondos propios desde el extranjero no tiene efectos impositivos al no constituir obtención de rentas. Los intereses que genere la cuenta bancaria en España quedan sujetos a tributación exclusivamente en Suiza según el artículo 11 del Convenio entre España y Suiza. Por tanto, no procede practicar retención en España conforme al artículo 31.4.a) del TRLIRNR.
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