Spanish Supreme Court Clarifies Tax Characterization of Payments for Client and Operational Data

Journal
OECD; Spain
Bulletin for International Taxation 2022 (Volume 76), No. 12
In this article, the author addresses a recent judgment of the Spanish Supreme Court (Tribunal Supremo, TS), of 24 June 2022, in which the tax characterization of payments for the use of client and operational data is clarified for Spanish treaty purposes.