Details of the new income and capital tax treaty and protocol between Spain and Germany, signed on 3 February 2011, have become available. The treaty was concluded in the Spanish and German languages, each text having equal authenticity. The treaty generally follows the OECD Model Convention. The maximum rates of withholding tax are: -   15% on dividends, in general, and 5% if the beneficial owner is a company (other than a partnership or a real estate investment company) holding directly at least 10% of the capital in the company paying the dividends (Art. 10(2) of the treaty). A limitation...