The amending protocol to 1990 income tax treaty between Spain and the U.S. will enter into force on 27 November 2019. The protocol, signed 14 January 2013, includes the following main changes: Paragraph 3 of Article 5 (Permanent Establishment) is replaced to provide that a building site or construction or installation project or drilling rig or ship used for the exploration of natural resources will constitute a permanent establishment if it lasts or the exploration activity continues for more than twelve months; Article 10 (Dividends) is replaced, including the following withholding tax rates: 0% if the beneficial owner is a...