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A company sought clarification on whether payments made to participants in bullfighting competitions (without an employment or commercial relationship) should be subject to income tax (IRPF) withholding. The DGT has ruled that, as these payments derive from an artistic activity, they are classified as income from professional activities and are therefore subject to withholding.
Question posed: Whether the amounts to be paid to participants (travel allowance and prizes) in a "bullfighting contest, considered a popular festival, in which the participants are NOT professionals and therefore does not involve social security registration or any type of employment or commercial link" are subject to personal income tax withholding.
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