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V0238-25 ·5 March 2025 ·consulta-vinculante Medium impact
Tax

Consulting fees for WHO not exempt due to non-functional status

A Spanish teacher earning consultancy fees from WHO asks whether her income is exempt. The DGT rules that, as she is not a WHO employee, the Convention exemption does not apply and she must be taxed under Spanish domestic law.

In 6 key points

How it affects those involved

Non-employee consultants working for international organizations like WHO are subject to Spanish taxation on their income.

Lifecycle

2025-03-05PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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