Panama
The tax treaty that Spain signed with Panama in Madrid on October 7, 2010, entered into force on July 25, 2011. Under the treaty, dividends are taxable at a maximum rate of 5 percent if the benefi cial owner is a company (other than a partnership) that directly holds at least 40 percent of the dividend payer’s capital; in other cases, a 10 percent rate applies. Dividends are exempt if they are distributed to a company whose capital is wholly or partly divided into shares and that directly holds at least 80 percent of the capital of the payer company where the company receiving the dividends meets certain qualifi cations. Interest and royalties are subject to a maximum rate of 5 percent. Effective from this date Panama is no longer considered a tax haven under Spanish domestic law.
Barbados
The tax treaty signed by Spain and Barbados on December 1, 2010, in Bridgetown entered into force on October 14, 2011. Under the treaty, dividends are taxable at 0 percent if the benefi cial owner is a company that holds directly 25 percent or more of the capital of the company paying the dividends. Dividends are taxed at 5 percent in all other cases. The branch remittance tax is limited to 0 percent. Interest and royalties are taxable only in the state of residency of the benefi cial owner. The defi nition of royalties includes rentals or leases of industrial, commercial and scientifi c equipment. Effective from this date Barbados is no longer considered a tax haven under Spanish domestic law.
Bahamas
The Bahamas-Spain TIEA signed in Nassau on March 11, 2010, entered into force on August 17, 2011. Effective from this date the Bahamas is no longer considered a tax haven under Spanish domestic law.
