In fiscal year 2021, Corporation S, which is a resident of the Spain, distributes dividends to its shareholder, Corporation A, which is a resident of Saudi Arabia, has no PE in Spain and has held a 10% participation interest in Corporation S since 2010.

Assuming that, according to Spanish domestic tax rules, a 20% withholding tax should apply to such outbound dividend, what would the Spanish tax treatment of such outbound dividend be?

		Spain will not levy any withholding tax
		Spain will levy its ordinary 20% withholding tax
		Spain will levy a withholding tax whose rate will not exceed 5%
		Spain will levy a withholding tax whose rate will not exceed 15%