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V0276-15 26 January 2015 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Professionals' fees for services to a company are deemed economic activity income

The nature of a professional partner's income from providing services to their company under the self-employed regime is examined. The DGT determines that, upon meeting LIRPF requirements, such income is classified as economic activity income and not as income from employment.

The question raised

Inquiry is made regarding the taxation of services provided by the partner to the company.

The DGT's ruling

Remuneration of directors is considered income from employment pursuant to Article 17.2.e) of the LIRPF. For professional partners, if they are included in the special Social Security regime for self-employed workers, their income is considered income from economic activities pursuant to Article 27.1 of the LIRPF. Transactions between related parties must be carried out at their normal market value.

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