Executive summaryThe Spanish Supreme Court (Tribunal Supremo) issued a decision (case number 1996/2019) on 23 September 2020, confirming the most recent case law regarding the limits on the dynamic interpretation of tax treaties.This decision is extremely relevant for the interpretation and application of tax treaties that have not been amended in line with the latest versions of the Organisation for Economic Co-operation and Development (OECD) Model Tax Convention (OECD MTC). In addition, it follows a case issued on 23 March 2020 (See EY Global Tax Alert, Spanish Supreme Court rules on limits to dynamic interpretation of tax treaties, dated 17 June 2020), which...