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V1294-26 27 May 2026 · SG de Fiscalidad Internacional Criterion in force
IRPF · exención fiscal

Fiscal exemptions for PNUD contracts not available without official status

A consultant asks whether income from a PNUD contract is tax-exempt. The DGT responds that, as not qualifying as an official under the 1946 Convention, no tax exemption applies.

The DGT's ruling

Remuneration derived from the contract cannot benefit from the tax exemptions provided in the Convention on the Privileges and Immunities of the United Nations of 13 February 1946. This is because the applicant does not hold the status of an official of the UNDP under said Convention, as indicated in her own contract.

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