Clifford Chance
New Spanish tax treatment on Spanish dividends received by non-Spanish hedge funds
23 May 2023
The Spanish Supreme Court has confirmed in five recent Decisions the application of a 1% withholding tax rate, instead of the general 19% withholding tax rate (or any applicable tax treaty reduced rate) to dividends obtained by EU hedge funds. This approach is similar to the one adopted for EU funds under the scope of the UCITs Directive and non-EU funds comparable to UCITs.
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