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V2401-25 ·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 auditors working abroad can apply the exemption under article 7 p) of the Corporate Income Tax Law without effective billing between entities. The DGT responds that the exemption depends on whether the intragroup service provides a benefit or utility to the non-resident entity, in accordance with corporate tax regulations.

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

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