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V1172-24 23 May 2024 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IVA · exención

Tax treatment of consultancy fees for the World Bank: VAT and IRPF exemptions under specific conditions

A professional resident in Spain seeks clarification on whether consultancy fees received from the World Bank are subject to VAT and IRPF. The DGT rules that the services are exempt from VAT due to an international agreement and that the income is exempt from IRPF provided the individual can prove their status as an official of a specialised agency.

The question raised

1.- Treatment of said fees for Value Added Tax purposes.

The DGT's ruling

Regarding VAT, the services are exempt pursuant to Article 22.9 of Law 37/1992 due to the tax immunity of the World Bank. Regarding Personal Income Tax (IRPF), salaries and emoluments are exempt if the taxpayer proves their status as an official of a specialized United Nations agency, in accordance with the applicable international conventions. However, the Personal Income Tax exemption is not applicable to periods for which the tax return filing deadline has already expired.

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