The Spanish High Court of Justice of Catalonia recently issued a decision regarding the eligibility of a Spanish tax resident for a tax exemption on dividend income under the Brazil-Spain tax treaty. The case involved a Spanish resident individual that received dividend income from a company in Brazil and was taxed on that income in Spain. The individual then sought a refund based on paragraph 3 of Article 23 (Methods for Elimination of Double Taxation) of the treaty, which provides that "Whe…