Spain – Ireland Tax Treaty
The Spain-Ireland tax treaty caps withholding on dividends at 15% for portfolio investors and 0% for qualifying direct investment, with interest payments fully exempt at 0%. Royalty rates vary by category, from 5% on copyright to 8% on film and television. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 40 active treaties in Spain's network and one of 33 in Ireland's. The general dividend rate of 15% compares to a median of 15% across Spain's network and 15% across Ireland's.
Verified data
Irish Revenue Commissioners (revenue.ie) - Double Taxation Treaties and Agreements (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12).)
Withholding Rate Summary
Source: Ireland Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Ireland) |
|---|---|---|
| Dividends (general) Portfolio investors | 15%saves 10% | 25% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 0%saves 25% | 25% |
| Interest Bank interest, bonds, loans | 0%saves 20% | 20% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 5.8% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (Ireland)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 15% applies to portfolio investors. A reduced rate of 0% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 25%.
Source: Ireland Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 0% withholding under this treaty, compared to the 20% statutory rate. Interest is fully exempt from source-country withholding under this treaty.
Source: Ireland Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 5% to 8%.
Source: Ireland Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: Ireland Treaty Reference
Comparative Context
🇪🇸Spain's Network
Among Spain's 40 active treaty partners, the 15% general dividend rate ranks 22th (median: 15%).
| Partner | Rate |
|---|---|
| United Kingdom | 15% |
| Hungary | 15% |
| Indonesia | 15% |
| Ireland (this treaty) | 15% |
| India | 15% |
| Italy | 15% |
| Japan | 15% |
🇮🇪Ireland's Network
Among Ireland's 33 active treaty partners, the 15% general dividend rate ranks 15th (median: 15%).
| Partner | Rate |
|---|---|
| Czech Republic | 15% |
| Germany | 15% |
| Denmark | 15% |
| Spain (this treaty) | 15% |
| Finland | 15% |
| France | 15% |
| United Kingdom | 15% |