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92 treaties · Dividends · Interest · Royalties

Spain's double tax treaties: every rate, in one table.

Spain has 92 double taxation treaties in force. Each one caps what Spain may withhold on dividends, interest and royalties leaving the country — and the caps vary from nothing at all to fifteen per cent. Search your country below, then read what the number does and does not mean.

Find your country ↗ Searchable, sortable, filterable by region
Treaties in force
92
Covering most of Spain's trading and investment partners.
Without a treaty
19% / 24%
Spanish domestic withholding: 19% for EU and EEA residents, 24% for others.
Lowest available
0%
Reached on all three income types in a handful of treaties, and by EU directive.
The short answer

What does a double tax treaty actually do?

It does two things. It allocates the right to tax a given kind of income between two countries, and where both may tax, it caps the rate the source country may charge and requires the residence country to give relief. For money leaving Spain, the practical effect is a ceiling: Spain's domestic withholding rate of 19% or 24% is replaced by whatever lower figure the treaty permits. The treaty never creates a tax that domestic law does not impose — it can only reduce one.

Almost every question we are asked about treaties is really one of three questions. What rate applies to my dividend, my loan interest or my licence fee. Whether I can get that rate without arguing about it. And which country gets to tax me at all, if both of them think they do. The table answers the first. The rest of this page answers the other two, because a rate you cannot actually obtain is not worth much.

One point before the numbers, because it is the most common misreading. Every figure below is a maximum, not a rate you are charged. It is the most Spain is permitted to withhold under that treaty. Spanish domestic law, or an EU directive, may already give you a better outcome — and where it does, you take the better one.

Every treaty, every rate.

Type a country name to filter, click a region to narrow, or click any column heading to sort by rate. Each row has its own link, so a specific country can be shared directly.

Showing all 92 treaties
Country ▲ Dividends
general		 Dividends
parent-subsidiary		 Min.
stake %		 Interest Royalties
Albania105/010/750/60
Algeria155100/57/14
Andorra155100/55
Argentina1510250/123/5/10/15
Armenia1002555/10
Australia1515—1010
Austria15105055
Azerbaijan105250/85/10
Barbados502500
Belarus100/5100/55
Belgium150250/105
Bolivia1510250/150/15
Bosnia and Herzegovina105200/77
Brazil1510250/10/1510/15
Bulgaria1552500
Canada155/0100/100/10
Cape Verde100250/55
Chile105205/155/10
China0/105250/1010
Colombia50200/5/1010
Costa Rica125200/5/1010
Croatia1502500
Cuba155250/100/5
Cyprus501000
Czech Republic1552500/5
Dominican Republic100750/1010
Ecuador1515—0/5/105/10
Egypt129250/1012
El Salvador120500/1010
Estonia155250/105/10
Finland0/1551000
France150100/100/5
Georgia1001000
Germany1551000
Greece105250/86
Hong Kong100250/55
Hungary1552500
Iceland155250/55
India1515—0/1510/20
Indonesia1510250/1010
Iran105200/7.55
Ireland1502505/8/10
Israel1010—0/5/105/7
Italy1515—0/124/8
Jamaica105250/1010
Japan0/5/100100/100
Kazakhstan155100/1010
Kuwait501005
Latvia105250/105/10
Lithuania155250/105/10
Luxembourg1510251010
Malaysia5050/105/7
Malta502500
Mexico100100/4.9/100/10
Moldova105/025/500/58
Morocco151025105/10
Netherlands151050106
New Zealand1515—1010
Nigeria107.5100/7.53.75/7.5
North Macedonia155100/55
Norway1510250/105
Oman100200/58
Pakistan107.5/525/500/107.5
Panama105/040/800/55
Paraguay0/105500/55
Philippines1510100/10/1510/15/20
Poland1552500/10
Portugal151025155
Qatar501000
Romania50100/33
Russian Federation1510/5by investment0/55
Saudi Arabia50250/58
Senegal1010—0/1010
Serbia105250/105/10
Singapore50100/55
Slovakia1552500/5
Slovenia155250/55
South Africa155250/55
South Korea1510250/1010
Sweden1510501510
Switzerland1501000/5
Thailand1010—0/10/155/8/15
Trinidad and Tobago105/025/500/85
Tunisia155505/1010
Turkey1552510/1510
United Arab Emirates1551000
United Kingdom1001000
United States0/155/010/800/100
Uruguay50750/105/10
Uzbekistan105/0250/55
Venezuela100250/4.95/105
Vietnam1510/725/500/1010
No treaty country matches that. Spain has no treaty with, among others, Denmark — see the note below.
Maximum rates the treaty permits Spain to withhold, in per cent. Where two or more figures appear, the treaty sets different rates for different cases — the article itself decides which applies. Rates as published June 2026; MLI effects not reflected.

How to read the numbers you just found.

Four columns, four different logics. Getting them confused is where most planning errors start.

What each column means
Dividends, general
The cap that applies to an ordinary shareholder. Usually 10% or 15%. This is the number that applies to you unless you hold a substantial stake.
Dividends, parent-subsidiary
A lower cap for a corporate shareholder holding at least the stated percentage, often for a minimum period. Frequently 0% or 5%.
Minimum stake
The holding needed to reach the parent-subsidiary rate. Where two figures appear, the treaty has two tiers. Several treaties also require a minimum holding period, or a minimum invested amount rather than a percentage.
Interest
Often shown as a pair such as 0/10. The zero is not general: it applies to defined categories — typically interest paid to or guaranteed by public bodies, bank and financial-institution lending, credit sales of equipment, and approved pension funds. Ordinary intercompany interest usually takes the higher figure.
Royalties
Frequently split by what is being licensed. A common pattern is a low rate for copyright, a middle rate for equipment leasing and a higher rate for patents, trademarks and know-how. Software can fall on either side and is a recurring source of dispute.
The mistake this table invites

A pair like 0/10 does not mean you can choose.

It means the treaty article contains conditions, and the condition decides. Reading "0/10" as "nil with the right structure" is how a 10% withholding becomes a surprise eighteen months after the loan was signed. The article text governs, and it is short enough to read.

When EU law beats the treaty.

For payments to another EU member state, the treaty is often not the relevant instrument at all. Two directives, transposed into Spanish law, can take the rate to zero where a treaty would still allow 5% or 10%.

Parent-Subsidiary Directive

Dividends at 0% on a 5% holding

Dividends paid by a Spanish company to an EU parent are exempt from Spanish withholding where both companies are subject to corporate tax in their member states, take a listed corporate form, and the parent holds at least 5% directly or indirectly for at least one year. The distribution must not arise from liquidation.

Interest and Royalties Directive

Royalties at 0% between associates

Royalties paid to an associated company in another member state may be exempt, generally requiring a direct 25% holding held for two years, beneficial ownership, and an arm's length amount. Separately, Spanish domestic law already exempts interest paid to EU lenders.

The condition attached to both

Anti-abuse rules, and they are applied.

Neither exemption survives a structure without substance. Spanish law contains a specific rule denying the dividend exemption where the majority of voting rights in the EU parent is held by non-EU residents and the parent's incorporation is not supported by valid business reasons. Neither directive applies where the recipient sits in a listed non-cooperative jurisdiction. A holding company with no people, no premises and no decisions is the fact pattern these rules were written for.

Getting the rate, not just qualifying for it.

A treaty rate is not automatic. Spanish payers withhold at the domestic rate unless they hold evidence entitling them to do otherwise, and the burden sits with the recipient to provide it before payment.

Step 01
Obtain a residence certificate that names the treatyNot a generic tax certificate. It must be issued by the recipient's tax authority and state that the holder is resident there for the purposes of the convention with Spain. Certificates without that wording are routinely rejected.
Step 02
Check its validity periodThese certificates generally have a limited life, commonly one year from issue. A certificate that has lapsed by the payment date does not support the reduced rate, and recurring payments need a renewal calendar.
Step 03
Give it to the payer before paymentRelief at source depends on the withholding agent holding the evidence when it withholds. Afterwards you are in refund territory, which is slower and requires the payer's cooperation.
Step 04
Establish beneficial ownershipNearly every treaty limits benefits to the beneficial owner. A conduit that receives and immediately passes the income on is not one, and this is the point on which structured arrangements most often fail.
Step 05
File where a form is requiredReduced rates and refunds run through the non-resident income tax forms. A refund claim is a filing, not a request, and it has its own deadline.

If the deadline has passed or the certificate arrived late, the position is usually recoverable through a refund claim — but it takes months, and it requires documents from a payer who by then has no commercial reason to help. Getting the certificate before the first payment is worth more than any amount of subsequent cleverness.

The tie-breaker: when two countries both claim you.

Withholding rates are the visible part of a treaty. The part that decides more money is the residence article, which resolves the case where each country's domestic law makes you resident. It runs as a sequence, and it stops at the first test that produces an answer.

01
Permanent homeWhere you have a home available to you on a continuing basis. If that is only one state, the analysis ends here — which is why keeping a home in both countries is expensive in ways people do not anticipate.
02
Centre of vital interestsWhere your personal and economic ties are closer. Family, employment, business, banking, memberships. This is a weighing exercise, and it is where most genuinely difficult cases are decided.
03
Habitual abode, then nationalityWhere you are physically present more regularly, and failing that, of which state you are a national. If nationality does not settle it either, the two authorities must agree between themselves.
A condition people miss

You cannot reach the tie-breaker unless both countries claim you.

The residence article applies only where you are resident under the domestic law of both states. If Spain considers you resident and the other country does not consider you resident at all, there is no tie to break and no treaty protection to invoke. This is the trap for people who leave a country without establishing residence anywhere else.

What treaties do not cover.

Treaty coverage is narrower than most people assume. These gaps account for a large share of the unpleasant surprises.

Outside almost every treaty

Inheritance and gift tax

Spain has only a handful of inheritance tax treaties. For most countries — including the United Kingdom and the United States — there is no relief mechanism at treaty level, and relief depends on domestic unilateral credits. Spanish succession tax also varies enormously by autonomous community.

Also outside

Social security, VAT and wealth tax

Social security is governed by separate bilateral agreements and EU coordination rules, not by tax treaties. VAT is outside the scope entirely. Wealth tax appears in only some treaties, so a Spanish wealth tax liability may exist with no treaty relief available at all.

Two structural points

The MLI, and the treaty that no longer exists.

Many of these treaties have been modified by the Multilateral Convention, which inserts a principal purpose test and other anti-abuse provisions without changing the text of the treaty itself. The rates in the table do not reflect it, and the consolidated position for a given pair of countries must be checked against both instruments.

Separately, note an absence: there is no Spain–Denmark treaty. It was terminated and has not been replaced, so payments between the two run on domestic rules. Absence from the table is not always an oversight.

Treaties analysed in depth.

Where we have written a full analysis rather than a rate line, it is linked here.

United KingdomPensions, government service, the absence of an inheritance treaty. IndiaRoyalties, technical services and permanent establishment risk. NetherlandsThe replacement convention authorised for signature in March 2026. FranceCross-border employment and permanent establishment. ItalyOne of the older conventions, with a 15% dividend rate and no parent-subsidiary reduction. BrazilTechnical services equated to royalties, and the treatment of JCP. MoroccoTrade flows, withholding and establishment questions. United StatesThe LLC problem: entity classification and treaty access.
Where this becomes a decision

The rate is easy. Qualifying for it is the work.

Residence certificates, beneficial ownership, substance and the interaction between a treaty, the directives and the MLI decide whether the number in this table is the number you actually pay. We check the position before the first payment, which is the only point at which it is cheap to fix.

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Terms you will meet
DTT / CDI
Double taxation treaty. In Spanish, convenio para evitar la doble imposicion.
Withholding tax
Tax deducted by the payer before the money leaves Spain, and paid over to the tax authority.
Beneficial owner
The person genuinely entitled to the income, as opposed to a conduit that passes it on. A condition in nearly every treaty.
Residence certificate
Proof of tax residence issued by the other state, which must refer to the convention with Spain to support a treaty rate.
Permanent establishment
A fixed place of business or dependent agent that gives Spain the right to tax business profits directly, outside the withholding regime.
MLI
The Multilateral Convention, which layers anti-abuse rules including a principal purpose test onto existing treaties.
Most-favoured-nation clause
A protocol provision under which a rate automatically falls if Spain later grants a better rate to a third country. Present in a number of Latin American treaties.
Non-cooperative jurisdiction
A listed territory. Its presence in a structure disapplies most exemptions and reliefs.
IRNR
Spanish non-resident income tax, the domestic regime a treaty modifies.
Frequently asked
How many double tax treaties does Spain have?
Ninety-two are in force, covering the EU, most of the Americas, much of Asia and the Middle East, and a smaller number of African states. Notable absences include Denmark, where the treaty was terminated and never replaced. Spain also has a separate and much shorter list of inheritance tax treaties, which are not the same instruments.
What is the withholding tax on dividends from Spain?
Spanish domestic law charges 19%. A treaty typically caps it at 10% or 15% for an ordinary shareholder, and often at 0% or 5% for a corporate parent meeting a minimum holding condition. For an EU parent holding at least 5% for a year, the Parent-Subsidiary Directive can remove the withholding entirely, which usually beats the treaty rate.
Does a treaty mean I only pay tax in one country?
Not usually. Treaties allocate taxing rights and cap source-country rates; they rarely give exclusive taxation to one state. The normal pattern is that the source country takes a limited amount and the residence country taxes the income again while giving credit for what was withheld. You generally still declare it at home.
What is the difference between the general and parent-subsidiary dividend rate?
The general rate applies to any shareholder. The parent-subsidiary rate is a lower cap available to a corporate shareholder holding at least the minimum stake shown, sometimes for a minimum period and sometimes with a minimum invested amount instead of a percentage. Individuals and partnerships are usually excluded from it even where their holding is large.
Why do the interest and royalty columns show two or three numbers?
Because the treaty article sets different caps for different cases. For interest, a zero typically covers public-body lending, bank lending, credit sales of equipment and approved pension funds, while ordinary interest takes the higher figure. For royalties, the split usually runs by what is licensed — copyright at the low end, patents, trademarks and know-how at the high end. The conditions in the article decide, not the payer.
Do I need a residence certificate to get the treaty rate?
In practice, yes. A Spanish payer must withhold at the domestic rate unless it holds evidence supporting a lower one, and the accepted evidence is a certificate from the recipient's tax authority stating residence for the purposes of the convention with Spain. Generic certificates without that wording are commonly refused, and the certificate must be valid on the payment date.
What happens if there is no treaty with my country?
Spanish domestic law applies unmodified: generally 19% for residents of the EU and EEA states with effective exchange of information, and 24% for others. Your own country may still give a unilateral credit for the Spanish tax, so double taxation is not always the result, but there is no cap on what Spain charges and no mechanism to resolve a residence conflict.
Do these rates apply to a Spanish branch?
No. Withholding rates apply to income obtained without a permanent establishment. A branch or other permanent establishment is taxed on its business profits under the ordinary corporate rules instead, and some treaties additionally limit the rate on remittances of branch profits. Whether an arrangement creates a permanent establishment is a separate and frequently contested question.
Does the MLI change these numbers?
Not the rates themselves, but it can change whether you are entitled to them. The Multilateral Convention inserts anti-abuse provisions, notably a principal purpose test, into many of Spain's treaties without amending the underlying text. A structure that satisfies the letter of a treaty article can still be denied benefits under it, so the consolidated position must be read against both instruments.
Is there a Spain-Denmark tax treaty?
No. The former convention was terminated and has not been replaced, so payments between Spain and Denmark are governed by domestic law on both sides, with relief depending on unilateral credits. This is unusual between two EU member states and it catches people out, although the EU directives still apply to qualifying corporate flows.
Rates compiled from published treaty summaries as at June 2026 and are maximum source-country rates for income obtained without a permanent establishment, given for orientation only. They do not reflect the Multilateral Convention, protocols concluded after that date, or most-favoured-nation clauses that may have been triggered. The text of the relevant convention governs in every case. General information, not tax or legal advice — verify the current position for your own facts before acting.
Continue reading

Treaties in practice.

Analysis
The UK-Spain conventionA full reading of one treaty, article by article.
Read guide ↗
Guide 02
Where residence beginsBefore a tie-breaker matters, one country has to claim you.
Read guide ↗
Guide 03
Modelo 210The return through which non-resident tax is actually paid.
Read guide ↗

Ninety-two treaties. Only one of them is yours.

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About the author
AB

Alexander Baranov

Founder, Voixa Consultors · International corporate structuring since 2008

Seventeen years designing and delivering cross-border corporate structures — incorporation, tax, holding, banking and market entry — for founders and companies expanding into Spain and the EU. Author of professional books on entering the Spanish market.

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