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A Spanish company sought clarification on whether the sale of machinery, including the transfer of intellectual property rights to a client in Thailand, was subject to withholding tax as royalties. The DGT ruled that, as it constitutes a full transfer of ownership resulting from work made for hire, the income is classified as business profits.
Question raised: Whether the operation carried out is subject to withholding tax in Thailand, in application of the Spain-Thailand Double Taxation Convention.
The income does not qualify as a royalty because it does not involve the use or granting of the use of a right, but rather a full transfer of ownership. The requirements of the Spain-Thailand Convention are not met to consider the gain as a royalty, as the price is certain and does not depend on the productivity or use of the machine. Therefore, the income is classified as business profits under Article 7 of the Convention. The profits may only be taxed in Spain, unless there is a permanent establishment in Thailand.
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