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A Spanish company asked whether payments for accounting services to a Malaysian entity constituted technical services subject to Spanish taxation. The DGT concludes that although these are technical services under the Convention, they do not originate in Spain as they are not materially provided on Spanish soil.
Question raised: Whether the remuneration paid to the applicant in payment for accounting services received from the Malaysian company falls within the concept of payment for technical services provided for in paragraph 4 of Article 12 of the Spanish-Malaysian Convention for the avoidance of double taxation, such that if they are understood to be provided in Spanish territory, they must be subject to taxation in Spain.
According to the Convention between Spain and Malaysia, payments for technical services are considered to originate from the State where they are materially provided. Accounting or financial services fall within the definition of technical services, but as they are not provided in Spain, they cannot be subject to taxation in this country. Therefore, the Spanish company must not apply withholding tax in accordance with the convention.
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