Skip to content
V1678-14 ·1 July 2014 ·consulta-vinculante Medium impact
Tax

US production company income from organising a concert is not taxable in Spain under certain conditions

A US company sought clarification on whether payments received for producing a concert in Spain should be taxed locally. The DGT ruled that, as these constitute technical production services rather than the personal activities of the artists, the artist clause of the Convention does not apply, and the income is only taxable in the US.

In 6 key points

How it affects those involved

This ruling clarifies that technical production services provided by foreign companies are treated as business profits rather than artist income, preventing double taxation under the relevant tax treaty.

Lifecycle

2014-07-01PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact