A ruling from Spain's General Directorate of Taxes was recently published concerning the exemptions from the taxation of capital gains by the source State under the 1966 Spain-Switzerland tax treaty. The ruling is in response to a request by a natural person resident in Switzerland that had sold their shares in a Spanish company that derived more than 50% of its value from immovable property in Spain. The Swiss resident sought clarification on whether the gain was taxable in Spain, considering that the company's activity was dedicated to the leasing of the immovable property. As provided by Article 13 (Capital...