The Ley del Impuesto sobre la Renta de No Residentes (Royal Legislative Decree 5/2004 of 5 March 2004 on Income Tax of Non-residents) provides that interest and other income from the transfer to third parties of own capital received by residents of an EU Member State, or by a permanent establishment (PE) of such entities situated in another Member State, will be tax exempt if paid by entities or P…