Taxation of Payments for the Acquisition of Software for Business Use for Spanish Treaty Purposes: Standard Software versus Customized Software and the Spanish Observation to the Commentary on Article 12 of the OECD Model

Abstract

This article considers the implications of the Spanish Observation to the Commentary on Article 12 of the OECD Model as it affects the taxation of payments for the acquisition of software for business use for Spanish treaty purposes, with special emphasis on the differing treatments of standard and customized software.