Skip to content
Back to index
V0976-15 27 March 2015 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · ganancia patrimonial

Argentina compensation taxed in Spain as patrimonial gain

A Spanish resident enquires about the tax treatment of compensation received from Argentina. The DGT determines that the income must be taxed in Spain as part of the general tax base under patrimonial gain.

The question raised

Tax treatment of said compensation.

The DGT's ruling

As the taxpayer is a resident in Spain, they are taxed on their worldwide income. The compensation, as it is not specifically provided for in the Convention with Argentina, is treated as 'other income' and may be taxed in both States. In Spain, the compensation constitutes a capital gain that is integrated into the general tax base, as it does not derive from a transfer of assets nor does it enjoy exemptions. The deduction for international double taxation of the tax effectively paid in Argentina is permitted.

Book your free first meeting