Venezuela and Spain signed a tax treaty on 8 April 2003. The treaty is in force as from 29 April 2004 and generally applies as of 1 January 2005. In respect of interest, Art. 11 of the treaty stipulates the right to tax of the State in which the interest arises, as follows: -   However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the interest, the tax so charged shall not exceed: (a) 4.95% of the...