Spanish Supreme Court Clarifies Tax Characterization of Payments for Client and Operational Data
Journal
Country
OECD; Spain
Published Date
Issue
Bulletin for International Taxation 2022 (Volume 76), No. 12
Document
In this article, the author addresses a recent judgment of the Spanish Supreme Court (Tribunal Supremo, TS), of 24 June 2022, in which the tax characterization of payments for the use of client and operational data is clarified for Spanish treaty purposes.