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On 16 July 2019, the United States Senate gave the green light to approving the Protocol (hereinafter "the Protocol") amending the Treaty between Spain and the United States on the avoidance of double taxation and the prevention of tax evasion, of 22 February 1990 (hereinafter "the Treaty").

This is undoubtedly a key milestone on the long road to ratification in order to promote investment and improve cross-border trade between the two countries.

1. Background

On January 14, 2013, Spain and the United States signed the Protocol, as well as a Memorandum of Understanding. Notes on error rectifications in the Protocol and the Memorandum were subsequently exchanged (23 July 2013 and 31 January 2014).

Since then, each Contracting State has had to follow an internal procedure until final ratification. In the case of Spain, in 2014, both the Congress and the Senate authorized the Government to consent to these texts without making any kind of amendment to them. In the United States, however, domestic procedure had been stalled in the Senate.

It is now for the President of the United States to sign the instrument of ratification and for both countries to notify each other through diplomatic channels that the internal procedure to be bound has been completed.

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