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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 2

Taxes Covered

(1) This Convention shall apply to taxes on income and on capital, imposed on behalf of each of the Contracting States, their political subdivisions or local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital, all taxes imposed on total income, total capital or items of income and capital, including taxes on gains from the alienation of movable and immovable property, taxes on the total amount of wages or salaries paid by the enterprise, as well as capital gains tax.

(3) The existing taxes to which this Convention shall apply are in particular:

  • (a) in Spain:
    • (i) income tax of individuals;
    • (ii) corporate tax;
    • (iii) income tax of non-residents;
    • (iv) capital tax; and
    • (v) local taxes on income and on capital;
  • (hereinafter referred to as "Spanish taxes");
  • (b) in El Salvador:
    • (i) income tax;
  • (hereinafter referred to as "Salvadorian taxes").

(4) This Convention shall also apply to taxes of an identical or substantially similar nature that are imposed after the date of signature of this Convention in addition to, or instead of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes made in their respective tax laws.