Tax Treaty: Canada and Spain Sign New Tax Protocol

By Robert Robillard - 18 November 2014

This blogpost originally appeared on

From Finance Canada website:

“Quick Facts

  • The Canada-Spain Income Tax Convention was signed on November 23, 1976.
  • The opening round of negotiations for a revised tax treaty between Canada and Spain was held in April 2007 in Madrid. A second round of negotiations was held in October 2008 in Ottawa.
  • Subsequent negotiations have resulted in the new Protocol being announced today.
  • The Protocol reduces withholding tax rates applicable on payments of dividends and interest and exempts from withholding tax certain payments of interest, and dividends paid to certain pension plans.
  • The Protocol also provides for assistance in the collection of taxes and includes provisions reflecting the Organisation for Economic Co-operation and Development standard for the exchange of tax information.
  • Canada and Spain will notify each other of the completion of their respective procedures, which are necessary for the entry into force of the Protocol.
  • The Protocol will enter into force after a period of three months following the date of receipt of the later of the notifications, and its provisions will have effect in accordance with Article 16 of the Protocol.
  • Canada has 92 tax treaties and 21 Tax Information Exchange Agreements in force, and has signed or is negotiating many more.”

See the Protocol Signed Between Canada and Spain here.

See the full text of 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


Robert Robillard, CPA, CGA, MBA, M.Sc. Econ.
Transfer Pricing Chief Economist, RBRT Inc.
514-742-8086; robert.robillard “at”

RBRT Inc. is all about transfer pricing. We specialize in transfer pricing, tax treaties and other international tax matters. Our services include transfer pricing documentation (transfer pricing policies and procedures, BEPS and C-doc), transfer pricing dispute resolution, tax treaty matters including double tax relief, tax treaty-based returns and waivers, advanced pricing agreement (APA), value chain management and TP planning, transfer pricing training. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. RBRT Inc. and the author are not responsible or liable for any error, omission or inaccuracy in such information. Readers should seek tax advice and tax counsel from RBRT Inc. as required.