Clarification on part of the Double Tax Treaty signed between Spain and Morocco


Recently there has been an exchange of letters between the Governments of Spain and Morocco with the aim of clarify the following points of the Convention between the Kingdom of Spain and the Kingdom of Morocco to avoid double taxation in respect of Personal Income Tax and Wealth Tax.

“– Regarding paragraph 2 c) of article 12 of the Convention, the expression “technical or economic studies” covers any analysis or specific technical or economic nature research, in which one of the parties undertakes to use their own knowledge, skills and experience to carry out itself the analysis or research without transferring this knowledge to the other party so that the latter cannot be used them for his own account.

For example, shall be considered technical or economic studies, the studies of financial risk, the financial studies and the studies made in the frame of professional activities as it architecture, it engineering, the legal advice, accounting or other type of consulting.

-the payments made by a resident of a contracting State in favour of an permanent establishment located in said State, with regard to the services rendered by the cited establishment permanent, not are subject to a withhold in the source whenever are attributable to said permanent establishment in accordance with the provisions of the article 7 of the Convention.”

-the tax authorities have emphasized the importance of the issuance of residence certificates to permit that residents within the meaning of the Convention to use the benefits of this Convention. 

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