The Supreme Court rules that several taxpayers, who were under the remittance basis taxation regime in the UK, should be considered tax resident in Spain according to the tie-breaker rules of the Double Taxation Convention between the two countries.
Tag: Double Taxation Convention
Tax advisor: The Supreme Court rules that tax residence conflicts between Spain and a country with a Double Taxation Agreement must be resolved according to the rules of the agreement
The Supreme Court, in its ruling of June 12, 2023, holds that the tax residence conflict must be resolved following the rules established in the Convention. Specifically, reference is made to Article 4.2 of the Convention, which establishes four successive criteria to determine the residence of a natural person in case he/she is a resident… Continue reading Tax advisor: The Supreme Court rules that tax residence conflicts between Spain and a country with a Double Taxation Agreement must be resolved according to the rules of the agreement