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Exchange of Notes between Morocco and Spain Signed

16 July 2015

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Treaty Development

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Morocco-Spain

An exchange of notes concerning certain provisions of the 1978 income and capital tax treaty between Morocco and Spain was signed by Spain on 11 June 2015 and by Morocco on 23 June 2015. The exchange of notes clarifies that payments for technical or economic studies under Article 12 (Royalties) includes analysis or research of a technical or economical nature where the party performing the analysis or research uses its own know-how without transferring the knowledge to the other party. It also clarifies that payments made by a resident of a Contracting State to a permanent establishment (PE) in that...