Executive summaryThe Spanish Supreme Court (Tribunal Supremo) issued a favorable decision confirming the right of a Canadian pension fund to obtain a refund of the Spanish withholding tax borne. The decision, dated 22 December 2020, was recently published.1The Canadian pension fund filed a reclaim to obtain a refund of the difference between the dividend withholding tax (DWHT) borne and the exemption applicable to Spanish pension funds, insofar as it implies discriminatory tax treatment for nonresidents in comparison with Spanish pension funds.The Spanish Supreme Court concluded that, at the time (2008), there was no regulatory framework that provided an equal treatment between Spanish...