2013European TaxationRequires access

Treaty Interpretation and Treaty Override: The Spanish Case Law on Royalties under the Spain-United States Income Tax Treaty (1990)

Ramírez Soriano

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Abstract

The author, in this article, summarizes the position of the Spanish tax authorities and courts on the interpretation of treaty terms under the pre-1995 version of article 3(2) of the OECD Model, in particular regarding the taxation of royalties, and discusses the possibility that such an interpretation constitutes treaty override.

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What this paper is about

The author, in this article, summarizes the position of the Spanish tax authorities and courts on the interpretation of treaty terms under the pre-1995 version of article 3(2) of the OECD Model, in particular regarding the taxation of royalties, and discusses the possibility that such an interpretation constitutes treaty override.

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Available abstract

The author, in this article, summarizes the position of the Spanish tax authorities and courts on the interpretation of treaty terms under the pre-1995 version of article 3(2) of the OECD Model, in particular regarding the taxation of royalties, and discusses the possibility that such an interpretation constitutes treaty override.

Key concepts: Treaty, Interpretation (philosophy), Tax treaty, Tax law, Political science, Law, Position (finance), Economics

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Treaty Interpretation and Treaty Override: The Spanish Case Law on Royalties under the Spain-United States Income Tax Treaty (1990) — Research Paper | ScholarLens