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Study of the agreement

Tax on Income of Non-residents

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INCOME

ALLOCATING FACTORS

OBTAINED BY MEANS OF A PERMANENT ESTABLISHMENT

Legislation and levying according to the Corporate Income Tax

OBTAINED WITHOUT A PERMANENT ESTABLISHMENT

Subject to the same legislation in terms of substance and form as in the Common Territory

From economic transactions or operations

Production in the Basque Country

From provision of services, technical assistance, management support services and professional services

Performance or usage in the Basque Country

Of the dependent work:

Personal interests:

Conducted in the Basque Country

Pensions and similar benefits:

From employment in Basque territory

Directors' Fees:

Exclusive taxation or on volume of operations

From artists or athletes

Personal performance in the Basque Country

From real property

Location of the property in the Basque Country

Capital gains

From real property or rights on it

Location of the property in the Basque Country

From other movable goods

Meeting or execution in the Basque Country

Capital earnings of public entities or persons

Dividends

From Basque public entities

Interests, royalties and other earnings on investments

Paid by individuals with habitual residence in the Basque Country or Basque public entities

Capital gains arising from securities

Issued by Basque public entities

Capital earnings of private entities or permanent establishments

Dividends

 

 

Entities operating only in the BC

Entities operating both in the BC and in the common territory

 

 

Exclusive taxation in the BC


Province holding the inspection jurisdiction of the non-resident representative

Interests, royalties and other earnings on investments

Capital gains arising from securities

Earnings obtained both in the BC and in the common territory

If payer is a legal person or a permanent establishment

If payer is an individual

Habitual residence of the payer in the Basque Country

Special Tax on Real Property of non-resident entities Location of the property
Special tax on the prizes of certain lotteries and bets Authority of the province where the point of sale is located where lottery ticket (“´decimo” or “cupón”) was bought or bet placed.