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V0075-26 ·20 January 2026 ·consulta-vinculante Medium impact
Tax

Foreign work exemption requires intragroup services to generate profit for non-resident entity

A Spanish engineer asks whether his annual three-day trips to Germany for work meetings qualify for exemption under article 7 p) of the IRPF law. The DGT states that, as a linked operation, it must be verified that the intragroup services generate an advantage or profit for the non-resident entity under Corporate Tax regulations.

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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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