“great discoveries and improvements invariably imply
the cooperation of many minds ”. Graham Bell.
Within international cooperation, there are also aspects related to the fiscal scope that approach, facilitate and promote the global investment flow in which we move today. One of the most prominent aspects in the transit of international capital are the double imposition agreements, rules established by countries and that determine how to declare the benefits obtained based on their origin.
Current tax systems cannot be understood or properly explained without considering the effects that the network of international agreements exerts on them to avoid the double imposition. The more than 3000 International Fiscal Agreements currently modulate, condition and determine decisively the exercise of the tax power of their contracting states.
The operation of double tax agreements
Double imposition agreements are of different kinds:
- Bilateral agreements to avoid double imposition and prevent tax evasion, which usually affect income taxes and heritage, although they change there are income from maritime and aerial navigation and on inheritances.
- Bilateral or multilateral agreements of which Spain is a party that affects the Spanish tax legal system.
- Agreements signed with international organizations that, even dealing with different matters, contain provisions that affect the fiscal scope.
Currently Spain has subscribed almost one hundred agreements of this type with many other countries with the objective of coordinating the taxation of these facts.
To correct the double imposition, an exemption method can be used, whereby the residence status of the receiver of the income renounces to tax the income obtained in another state, or the imputation method, by which the perceived income perceived In a state it is included in the taxable base of the perceptor to the object of its tax by the state of residence.
In the second method, the satisfied tax in the state of origin (total imputation) or the tax that would be satisfied in the state of residence if the income had been obtained in it (partial imputation),
The double -imposition agreements signed by Spain are with Albania, Germany, Saudi Arabia, Algeria, Argentina, Armenia, Australia, Austria, Barbados, Belgium, Bolivia, Bosnia and Herzegovina, Brazil, Bulgaria, Canada, Munch, Chile, Chile, Chile, China, Chipre, Colombia, South Korea, Costa Rica, Croatia, Cuba, Denmark, Ecuador, Egypt, United Arab Emirates, Slovakia, Slovenia, United States, Estonia, Philippines, Finland, France, Georgia, Greece, Holland, Hungary, India, Indonesia, Iran, Ireland, Iceland, Israel, Italy, Jamaica, Japan, Kazakhstan, Kuwait, Latvia, Lithuania, Luxembourg, Macedonia, Malasia, Malta, Morocco, Mexico, Moldavia, Nigeria, Norway, New Zealand, Pakistan, Panama , Poland, Portugal, United Kingdom, Russian Federation, Dominican Republic, El Salvador, Romania, Senegal, Serbia, Singapore, South Africa, Sweden, Switzerland, Thailand, states of the former USSR (except Russia), Trinidad and Tobago, Tunisia, Turkey , Uruguay, Venezuela, Vietnam.
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Mariano Rajoy (Spain) with Theresa May (Great Britain) .- The country.