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V0229-17 31 January 2017 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · renta mundial

Experts' EU payments taxed as worldwide income

A professor asks whether payments from evaluating EU projects are subject to Spanish personal income tax. Hacienda replies that as a Spanish resident, he must pay tax on his worldwide income, and such earnings do not benefit from the foreign work exemption.

The question raised

Question posed: Whether said remuneration is subject to Personal Income Tax and, if so, its tax treatment.

The DGT's ruling

The remuneration of European Commission experts is subject to Personal Income Tax (IRPF) under the principle of worldwide income. The exemption for work performed abroad under Article 7.p) of the Personal Income Tax Law (LIRPF) does not apply because the contracts stipulate that they do not constitute an employment relationship. The classification of these earnings as income from employment or from economic activities will depend on whether the taxpayer organizes production factors on their own account.

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