Spain / taxation - Protocol between Canada and the Kingdom of Spain amending the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital signed at Ottawa : Espagne / imposition - Protocole entre le Canada et le Royaume d'Espagne modifiant la Convention entre le Canada et l'Espagne, tendant áa âeviter les doubles impositions et áa prâevenir l'âevasion fiscale en matiáere d'impãots sur le revenu et sur la fortune signâee áa Ottawa le 23 novembre 1976

However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partn [...] Nothing in this Convention shall be construed as preventing a Contracting State from imposing on the income from the alienation of immovable property situated in that State by a company that is a resident of the other Contracting State carrying on a trade in immovable property, a tax in addition to the tax that would be chargeable on the income of a company that is a resident of the first-mentione [...] However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the interest.” 2. Paragraph 7 of Article XI (Interest) of the Convention shall be deleted and replaced by the fol [...] Notwithstanding the provisions of paragraph 2: (a) interest arising in a Contracting State and paid to a resident of the other Contracting State shall not be taxable in the first-mentioned Contracting State if the beneficial owner of the interest is a resident of the other Contracting State and is dealing at arm’s length with the payer; (b) interest arising in Spain and paid to a resident of Canad [...] The provisions of paragraph 2 shall not apply if the recipient of the dividends, being a resident of a Contracting State, carries on in the other Contracting State of which the company paying the dividends is a resident, a trade or business through a permanent establishment situated therein and the holding by virtue of which the dividends are paid is effectively connected with such permanent estab