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V2400-25 ·10 December 2025 ·consulta-vinculante Low impact
Tax

Foreign work exemption requires intragroup service to provide benefit or utility to non-resident entity

A company asked whether workers sent abroad can benefit from exemption under article 7 p) of the IRPF Law without effective billing between group entities. The DGT responds that the exemption depends on whether the activity constitutes an intragroup service that provides a benefit or utility to the non-resident entity.

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Lifecycle

2025-12-10PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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