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V0596-18 ·6 March 2018 ·consulta-vinculante Medium impact
Tax

Professional activity in a Spanish law firm may constitute a permanent establishment subject to IRNR

A Spanish lawyer who moves to the UK asks whether prior professional activity in Spain creates a permanent establishment. The DGT states that the law firm could be considered a permanent establishment, and if the individual is a non-resident, they must pay tax on those revenues through the IRNR.

In 6 key points

How it affects those involved

Non-residents carrying out professional activities through a Spanish law firm may be subject to Spanish IRNR tax on income derived from Spain, depending on whether the firm constitutes a permanent establishment.

Lifecycle

2018-03-06PublishedPublished 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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