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V1794-24 ·17 July 2024 ·consulta-vinculante Medium impact
Tax

IRPF exemption under art. 7p not applicable to mercantile service contracts with foreign work

A Spanish resident providing services to a foreign company via a mercantile contract and issuing monthly invoices asks whether the exemption under art. 7p of the IRPF applies. The DGT concludes that the exemption requires a labour or statutory relationship characterised by independence; since the income arises from economic activities under a mercantile service contract, the exemption does not apply.

In 6 key points

How it affects those involved

The exemption under article 7p of the IRPF does not apply to income from mercantile service contracts, even when services are performed abroad.

Lifecycle

2024-07-17PublishedPublished 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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