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A consultancy asks whether employees working abroad for international group offices in administration or HR can benefit from exemption under article 7 p) of the IRPF law. The DGT states that exemption applies only if services are genuinely rendered abroad, to a non-resident entity, in a country with an analogous tax system, not a tax haven, and if the activity constitutes a group service that provides benefit or utility to the recipient entity.
The ruling clarifies conditions for IRPF exemption on foreign group services, emphasising genuine cross-border activity and benefit to the recipient entity.
The tax team reviews your specific situation.
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