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V0680-26 26 March 2026 · SG de Impuestos sobre el Consumo Criterion in force
IVA · actividad económica

Administrator and board member remuneration generally exempt from VAT

The DGT confirms that payments to a president and board member are generally not subject to VAT as these activities are not carried out independently and do not entail independent economic risk.

The question raised

Liability to Value Added Tax of the remuneration received by the applicant for their positions as chairman and member of the board of directors.

The DGT's ruling

The activity of a director or member of the board of directors is not subject to VAT if it is not carried out independently. For liability to exist, the professional must act in their own name, on their own account, under their own responsibility, and bear the direct economic risk of their activity. In the case of directors, the company is the entity that bears the negative consequences of decisions, therefore the requirement of independence is not met.

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