One of the typical controversial issues in the Spanish tax system has traditionally been tax refunds to non-residents, where the refund is based on tax treaty provisions. This was contentious because under the Spanish General Taxation Law, resident taxpayers are entitled to claim a refund of any taxes incorrectly paid within a four-year period (before 1998, five years), a time limit that applied to non-residents, but only where they did not claim the refund under the provisions of a specific tax treaty (either because they were not resident in a country with which Spain had a tax treaty or because they were not entitled to it). In the latter case, the time limits were traditionally shorter.
November 01 2005