On 30 September and 1 October 2013, two binding rulings were published in the Official Journal (No. 5,360 and 5,494) with respect to withholding tax on payments for services to non-residents. In general, taxpayers subject to corporate income tax (impuesto a las rentas de las actividades económicas, IRAE) must withhold the non-residents income tax (impuesto a la renta de los no residentes, IRNR) on payments for services performed abroad. In general, the withholding tax is not deductible for corporate income tax purposes. According to Rulings No. 5,360 and 4,494, where the withholding agent is legally obliged to bear the withholding...