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V3150-15 ·19 October 2015 ·consulta-vinculante Medium impact
Tax

Commission from agency exempt from IRNR if no permanent establishment

The consultant asks whether IRNR should be withheld on commission paid to an artist agency. The DGT states that if the commission is for intermediation and the agency has no permanent establishment in Spain, the income is exempt under the OECD Model Convention.

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2015-10-19PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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