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The DGT confirms that professional services are taxed in France (except where a fixed base exists in Spain) and dividends are taxed in Spain under the IRNR.
Question raised: The following is posed:
Income from professional services provided by a resident in France is taxed in France, unless they have a fixed base in Spain for their activity. Dividends paid by the Spanish company are considered income obtained in Spain and are taxed under the Non-Resident Income Tax with a maximum rate of 15%. If the partner does not have a permanent establishment, the entity must use form 216 and the partner must use form 210.
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