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The DGT determines that remuneration for managerial roles is earnings from labour, and payments for business activities are likewise considered earnings from labour if they do not meet the criteria for economic activities.
Question posed: The inquiry concerns the taxation applicable to said partners for the services rendered to the company.
Remuneration for the position of director constitutes income from employment pursuant to Article 17.2.e of the Personal Income Tax Law (LIRPF). Income from services other than those as a director, derived from the company's business activity, also constitutes income from employment as they do not meet the requirements for economic activities under Article 27.1. This remuneration must be valued at its normal market value.
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