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A French resident student carrying out training in a Spanish company asks whether their income is exempt under the France-Spain double taxation treaty. The DGT responds that as the income is sourced in Spain, the exemption does not apply and it is taxable in Spain.
Cuestión planteada
Las cantidades para estudios o formación de un estudiante residente en otro Estado contratante no tributan en el Estado donde se encuentra si proceden de fuentes situadas fuera de este. Al ser rentas del trabajo derivadas de una actividad personal en España, no cumplen el requisito de procedencia externa y tributan por el IRNR. La empresa española debe practicar una retención del 19% por tratarse de un residente en la Unión Europea.
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