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A company providing services in the United Arab Emirates has requested clarification on whether receiving income through a Spanish current account carries tax implications. The DGT has ruled that no Non-Resident Income Tax (IRNR) is due in Spain if the entity is a resident of the UAE, and that the bank account does not constitute a permanent establishment for VAT purposes.
Question posed: Does the collection of payments for services rendered in the United Arab Emirates through a current account opened with a financial institution located in Spanish territory have any tax implications in Spain, regarding both direct and indirect taxation?
En materia de IRNR, si la empresa es residente en Emiratos Árabes Unidos y solo realiza su actividad allí, sus beneficios no tributan en España según el Convenio para evitar la doble imposición. Respecto al IVA, la mera titularidad de una cuenta corriente en una entidad financiera española no determina la existencia de un establecimiento permanente en territorio español.
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