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V0252-15 22 January 2015 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Administrator remuneration is earnings from work and professional services

The DGT clarifies that payments for the role of administrator are earnings from work, and professional services may be considered economic activities if certain social security requirements are met.

The question raised

An inquiry is made regarding the taxation of services provided by the aforementioned partners to the company.

The DGT's ruling

Remuneration for the position of director is considered income from employment pursuant to the Personal Income Tax Act (LIRPF), even if the position is unpaid. Professional services provided by partners may constitute income from economic activities if the taxpayer is included in the special Social Security regime for self-employed workers or an alternative mutual insurance scheme. Transactions between these related parties must be valued at their fair market value.

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