Convention between the Republic of Latvia and the Kingdom of Spain for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital
| Coming into Force | 14 December 2004 |
| Subject Terms | Taxation |
| Date of Conclusion | 04 September 2003 |
| Registration Date | 16 May 2005 |
| Registration Number | 41327 |
| Type of Document | Bilateral |
| Participants | Latvia,España |
| Party Submitting the Application for Registration | Latvia |
No.
41327
Latvia
and
Spain
Convention
between
the
Republic of
Latvia
and
the
Kingdom
of
Spain
for
the
avoidance
of
double
taxation
and
the prevention of
fiscal evasion with
respect
to
taxes
on
income
and
on
capital
(with
protocol).
Riga,
4
September
2003
Entry
into
force:
14
December
2004
by
notification,
in
accordance
with
article
29
Authentic
texts:
English,
Latvian
and
Spanish
Registration
with the
Secretariat
of
the
United
Nations:
Latvia,
16
May
2005
Lettonie
et
Espagne
Convention
entre
la
Republique
de
Lettonie
et
le
Royaume
d'Espagne tendant
A
6viter
la
double
imposition
et
A
prevenir
1'6vasion
fiscale
en
matiere
d'imp6ts sur
le
revenu
et
sur
la
fortune
(avec
protocole).
Riga,
4
septembre
2003
Entree
en
vigueur
:
14
d~cembre
2004
par
notification, conformi~nent
6
Particle
29
Textes
authentiques
:
anglais,
letton
et
espagnol
Enregistrement
aupres
du
Secr6tariat
des
Nations
Unies
:
Lettonie,
16
mai
2005
Volume
2313.
1-41327
[
ENGLISH
TEXT
-
TEXT
ANGLAIS
]
CONVENTION
BETWEEN
THE
REPUBLIC
OF
LATVIA AND
THE
KING-
DOM
OF
SPAIN
FOR
THE
AVOIDANCE
OF
DOUBLE
TAXATION
AND
THE
PREVENTION
OF
FISCAL
EVASION
WITH
RESPECT
TO
TAXES
ON
INCOME AND
ON
CAPITAL
The
Republic
of
Latvia and
the
Kingdom
of
Spain,
Desiring
to
conclude
a
Convention
for
the
avoidance
of
double
taxation
and
the pre-
vention
of
fiscal
evasion
with
respect
to
taxes
on
income
and
on
capital,
Have
agreed
as
follows:
CHAPTER
1.
SCOPE
OF
THE
CONVENTION
Article
1.
Per.sons
Covered
This
Convention
shall
apply
to
persons
who
are
residents
of
one
or
both
of
the
Con-
tracting States.
Article
2.
Taxes
Covered
1.
This
Convention
shall
apply
to
taxes ol
income
and
on
capital
imposed
on
behalf
of
a
Contracting
State
or
of
its
political
subdivisions
or
local
authorities,
irrespective
of
the
manner
in
which
they
are
levied.
2.
There shall
be
regarded
as
taxes
on
income
and
onl
capital
all
taxes
imposed
on
total
income,
on
total capital,
or
on
elements
of
income or
of
capital,
including
taxes
on
gains
from the
alienation
of
movable or
immovable
property,
as
well
as
taxes
on
capital
appreci-
ation.
3.
The
existing
taxes
to
which the
Convention
shall
apply
are
in
particular:
a)
in
Spain:
(i)
the
income
tax
on
individuals
(Inpuesto
sobre
la
Renta
de
las
Personas
Fisicas);
(ii)
the
corporation
tax
(Impuesto
sobre
Ia
Renta
de
Sociedades)
(iii)
the
income
tax
on
non
residents
(Impuesto
sobre
la
Renta de no
Residentes);
(iv)
the
capital
tax
(Impuesto
sobre
el
Patrimonio);
(v)
local
taxes
on
income
and
on
capital (impuestos
locales
sobre
la
renta
y
sobre
el
patrimonio);
(hereinafter
referred
to
as
"Spanish
tax"):
b)
in
Latvia:
(i)
the
enterprise
income
tax
(uznemumu
ienakuma
nodoklis);
(ii)
the
personal income
tax
(iedzivotaju
ienakuma
nodoklis);
(iii)
the
immovable
property
tax
(nekustama
ipasuma
nodoklis);
Volume
2313,
1-41327
(hereinafter
referred
to
as
"Latvian
tax").
4.
The
Convention
shall
apply also
to
any
identical
or
substantially
similar
taxes
that
are
imposed
after
the
date
of
signature
of
the
Convention
in
addition
to,
or
in
place
of,
the
existing
taxes.
The
competent authorities
of
the
Contracting
States
shall
notify
each other
of
any
significant
changes
that
have been
made
in
their
taxation
laws.
CHAPTER
II.
DEFINITIONS
Article
3.
General
Definitions
1.
For
the
purposes
of
this
Convention,
unless
the
context
otherwise
requires:
a)
the term
"Spain"
means
the
Kingdom
of
Spain
and,
when used
in
the
geographical
sense,
comprises
the
land
territory,
inland
waters and
the
territorial
sea,
as
well
as
maritime
areas
outside
the
territorial
sea
of
Spain
over which,
in
accordance
with
International
law,
they exercise and/or
may
exercise
jurisdiction
and
sovereign
rights;
b) the
term
"Latvia" means the Republic
of
Latvia
and,
when
used
in
the
geographical
sense, comprises
the
land
territory,
inland
waters and
the
territorial
sea, as well
as
maritime
areas
outside
the
territorial
sea
of
Latvia
over which,
in
accordance
with International
law,
they exercise and/or
may
exercise
jurisdiction
and
sovereign
rights;
c)
the terms
"a
Contracting
State"
and
"the
other
Contracting
State" mean Latvia
or
Spain,
as
the
context requires;
d) the
term
"person" includes
an
individual,
a
company
and
any
other
body
of
persons;
e)
the term
"company" means
any
body
corporate or
any
entity which
is
treated
as a
body
corporate
for
tax
purposes;
t)
the
terms
"enterprise
of
a
Contracting
State"
and
"enterprise
of
the
other Contracting
State"
mean
respectively
an
enterprise
carried
on
by
a
resident
of
a
Contracting
State
and
an
enterprise
carried
on
by
a
resident
of
the
other
Contracting
State;
g)
the
term
"international
traffic"
means
any
transport
by
a
ship
or aircraft operated
by
an
enterprise
of
a
Contracting
State,
except
when
the
ship or
aircraft
is
operated
solely
be-
tween
places
in
the
other
Contracting
State;
h)
the
term
"competent
authority"
means:
(i)
in
Spain,
the
Minister
of
Finance
or
his
authorised
representative;
(ii)
in
Latvia,
the
Ministry
of
Finance or
its
authorised
representative;
i)
the term "national" means:
(i)
any
individual
possessing
the
nationality
of
a
Contracting
State;
(ii)
any
legal
person,
partnership
or association
deriving
its
status
as
such
from
the
laws
in
force
in
a
Contracting
State.
2.
As
regards
the
application
of
the
Convention
at
any
time
by
a
Contracting
State,
any
term
not
defined therein
shall, unless
the
context
otherwise
requires,
have
the
meaning
that
it
has
at
that
time
under
the
law
of
that
State
for
the
purposes
of
the
taxes
to
which
the
Con-
vention
applies,
any
meaning
under
the
applicable
tax laws
of
that
State
prevailing
over
a
meaning
given
to the
term
under other
laws
of
that
State.
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