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A securities firm queries the treatment of income from non-resident clients using derivatives instruments (options, futures, swaps, CFDs, etc.) under IRNR. The DGT states that if no economic activity exists, such income is considered 'other income' and is taxable only in the country of residence.
Cuestión planteada Se plantean diversas cuestiones relativas al tratamiento en el Impuesto sobre la Renta de no Residentes de las operaciones sobre los derivados señaladas en la descripción de hechos, las cuales se detallan en el propio cuerpo de la contestación.
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