The Spanish National High Court (Audiencia Nacional), in its Judgment dated 28 April 2022, recently published, has confirmed the right of a sovereign fund to obtain the refund of dividend withholding taxes (DWHT) imposed as Nonresident Income Tax (NRIT) derived from its investments in Spain.The taxpayer in this case was a non-European sovereign fund investing in Spain through two different investment vehicles, one of the vehicles was comparable to the Spanish Fund for Foreign Investment (FIEX) and the other one comparable to the Fund to Support the Diversification of the Fishing and Aquaculture Industry (FADSPA), that are public bodies.While the...