Spain vs COLGATE PALMOLIVE ESPAÑA, S.A., November 2018, Audiencia National, Case No 643/2015 – ECLI:EN:AN:2018:5203

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Category: Beneficial Owner, Royalty and License Payments, Tax Treaty Interpretation, Withholding Tax (WHT) | Tag: , , , , , , , ,
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The tax authorities had issued an assessment according to which royalty payments from Colgate Palmolive España S.A. (CP España) to Switzerland were not considered exempt from withholding taxes under the Spanish-Swiss DTA since the company in Switzerland was not the Beneficial Owner of the royalty-income.

Judgement of the National Court

The court held in favour of Colgate and set aside the decision of the tax authorities.

SP vs Palmolive SAN_1128_2018 ENG NW”>Click here for English Translation

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SAN_5203_2018

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