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Spain โ€“ Italy Tax Treaty

The Spain-Italy tax treaty caps withholding on dividends at 15%, and interest at 12%. Royalties are taxed at a uniform 8% across all categories. 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 47 in Italy's. The general dividend rate of 15% compares to a median of 15% across Spain's network and 15% across Italy's.

Verified data

Agenzia delle Entrate (agenziaentrate.gov.it) - Double Taxation Conventions and treaty texts (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12).)

Withholding Rate Summary

Source: Italy Treaty Reference
Income TypeTreaty RateStatutory Rate (Italy)
Dividends (general)

Portfolio investors

15%saves 11%26%
Dividends (qualified)

Beneficial owner is a company holding >= 10% of voting stock

15%saves 11%26%
Interest

Bank interest, bonds, loans

12%saves 14%26%
Royalties (avg)

Patents, copyright, know-how, film/TV

8%โ€”
Pensions

Private pension distributions

0%โ€”
Social Security

Government social security benefits

0%โ€”

โ€œTreaty Rateโ€ is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. โ€œStatutory Rate (Italy)โ€ 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
General Rate15%saves 11% vs statutory
Qualified Rate15%saves 11% vs statutory
Statutory Rate26%without treaty

The general dividend rate of 15% applies to portfolio investors. A reduced rate of 15% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 26%.

Source: Italy Treaty Reference

Interest
Treaty Rate12%saves 14% vs statutory
Statutory Rate26%without treaty

Interest payments (bank interest, bonds, loans) are subject to 12% withholding under this treaty, compared to the 26% statutory rate. This represents a 14% reduction from the statutory rate.

Source: Italy Treaty Reference

Royalties
Know-how8%
Patents8%
Film & TV8%
Copyright8%

Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 8% to 8%.

Source: Italy Treaty Reference

Pensions & Social Security
Pensions0%exempt at source
Social Security0%exempt at source

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: Italy Treaty Reference

Comparative Context

๐Ÿ‡ช๐Ÿ‡ธSpain's Network

Among Spain's 40 active treaty partners, the 15% general dividend rate ranks 24th (median: 15%).

PartnerRate
Indonesia15%
Ireland15%
India15%
Italy (this treaty)15%
Japan15%
South Korea15%
Luxembourg15%

๐Ÿ‡ฎ๐Ÿ‡นItaly's Network

Among Italy's 47 active treaty partners, the 15% general dividend rate ranks 21th (median: 15%).

PartnerRate
Germany15%
Denmark15%
Egypt15%
Spain (this treaty)15%
Finland15%
France15%
United Kingdom15%

Frequently Asked Questions

What is the dividend withholding rate under the Spain-Italy tax treaty?
The general dividend withholding rate is 15%. A reduced rate of 15% applies when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory rate is 26%. Source: Italy Treaty Reference.
What is the interest withholding rate between Spain and Italy?
The treaty rate on interest is 12%, compared to the 26% statutory rate. Source: Italy Treaty Reference.
How are pensions taxed under the Spain-Italy treaty?
The treaty withholding rate on pensions is 0%. Source: Italy Treaty Reference.

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