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V0357-22 24 February 2022 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Providing courses through a third-party organiser is taxed as employment income

A civil servant providing courses for consultancy firms has enquired whether this income should be taxed as employment income or as income from economic activities. The DGT has ruled that, as the organisation is carried out by a third party, it is classified as employment income.

The question raised

For the purposes of Personal Income Tax (IRPF), it is asked whether the taxation as income from employment of the amounts obtained from the provision of said courses is correct.

The DGT's ruling

The provision of courses is, as a general rule, income from employment, unless it involves the self-organized management of means of production or human resources. Classification as an economic activity depends on whether the taxpayer acts as an organizer or if the activity is part of an already existing economic activity. If the organization is carried out by a third party, the income is classified as income from employment.

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