Skip to content
Back to index
V1220-14 7 May 2014 · SG de Fiscalidad Internacional Criterion in force
IRPF · residencia fiscal

Norwegian pension for a Spanish resident taxed only in Spain

A Spanish tax resident of Norwegian nationality asks whether their pension from public service in Norway is subject to Spanish taxation. The DGT states that, under the Spain-Norway double taxation agreement, such pension is only taxable in the country of residence.

The question raised

Whether the pension received from Norway, for services rendered as a civil servant in that State, must be taxed in Spain.

The DGT's ruling

In accordance with Article 18 of the Convention between Spain and Norway, pensions paid by a Contracting State to a resident of the other State shall be taxable only in that other State. As it is a pension, Article 19.1.a) does not apply, which expressly excludes this type of income. Therefore, the pension originating from Norway may only be taxed in Spain.

Free assessment and quote