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V0067-26 ·20 January 2026 ·consulta-vinculante Medium impact
Tax

Foreign work exemption requires intragroup service with benefit to foreign entity

An employee of a Spanish company asks whether the exemption for work performed in a US subsidiary applies. The tax authority determines that the query is inadmissible as premature for 2024, and for 2025 the exemption requires proof that the work constitutes an intragroup service providing benefit to the foreign entity.

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2026-01-20PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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