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V0423-22 3 March 2022 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Payments to experts for courses and reports generally constitute income from work

The DGT confirms that payments to expert staff for training and technical reports are generally income from work, unless the expert organises the means of production independently, and examines the exemption for work carried out abroad.

The question raised

1.- Whether the classification of the income paid by the applicant to the public officials of AESA, by virtue of the specific Agreement of July 2020, is that of employment income.

The DGT's ruling

Income from providing courses, lectures, or seminars constitutes employment income, unless the taxpayer organizes their own means of production or human resources. In the case of experts who do not organize the event, the income is classified as employment income. If these activities are performed abroad for non-resident entities and the requirements of territoriality and tax treaty are met, they may be exempt under Article 7 p) of the Personal Income Tax Law (LIRPF).

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