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V2128-24 ·2 October 2024 ·consulta-vinculante Medium impact
Tax

Spanish company must withhold 24% IRNR on UK-resident manager's remuneration

A Spanish limited company asks about withholding taxes on remuneration of its UK-resident manager exercising duties remotely. The DGT concludes that Spain may tax such remuneration under the Spain-UK CDI and TRLIRNR, with a 24% retention to be declared via forms 216 and 296.

In 6 key points

How it affects those involved

Spanish companies with UK-resident managers must withhold 24% on administrative remuneration and declare it via forms 216 and 296 under the Spain-UK CDI and TRLIRNR.

Lifecycle

2024-10-02PublishedPublished 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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