Skip to content
Back to index
V0277-15 26 January 2015 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Managerial remuneration is earnings from work; professionals' services are economic income

The nature of profits from partners acting as managers and professionals is examined. The DGT states that payments for the managerial role constitute earnings from work, and professional services rendered by partners are earnings from economic activities.

The question raised

Inquiry regarding the taxation of services provided by the aforementioned partners to the company.

The DGT's ruling

Remuneration for administrator functions is considered income from employment pursuant to Article 17.2.e) of the LIRPF, even if the position is unpaid. Services provided by professional partners, by organizing means of production on their own account and being registered as self-employed, constitute income from economic activities. Transactions between the company and the partners must be carried out at their normal market value as they are related parties.

Free assessment and quote