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A Spanish company asks whether it must withhold taxes on Argentine residents providing independent services from abroad. The DGT responds that since no activity is carried out in Spain and no fixed base exists here, the income is exempt under the double taxation treaty.
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Según el Convenio hispano-argentino, las rentas por servicios profesionales de residentes en Argentina solo tributan en España si la actividad se realiza en este país o si existe una base fija. Si los servicios se prestan desde Argentina, España no puede gravar esas rentas. En consecuencia, la empresa pagadora no debe practicar retención ni ingreso a cuenta, aunque mantiene la obligación de presentar la declaración correspondiente.
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