In this case note, the author addresses two new judgments of the Spanish Tribunal Supremo (Supreme Court) of 3 March and 23 September 2020, in which limitations on the dynamic interpretation of model-based tax treaties were developed.
In this case note, the author addresses two new judgments of the Spanish Tribunal Supremo (Supreme Court) of 3 March and 23 September 2020, in which limitations on the dynamic interpretation of model-based tax treaties were developed.