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The taxpayer asks which withholding tax rate should be applied to payments received for image rights following participation in an advertisement. The DGT rules that a 24 per cent withholding tax applies to the gross income.
Cuestión planteada - Retención aplicable sobre el importe correspondiente a los derechos de imagen.
La retención e ingreso a cuenta sobre los rendimientos procedentes de la cesión del derecho a la explotación del derecho de imagen, sea cual sea su calificación, es del 24 por ciento. Este porcentaje se aplica sobre los rendimientos íntegros que se satisfagan.
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