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A car repair business partner and manager seeks tax advice. The DGT rules that both management and service fees, due to lack of economic activity criteria, are considered income from work.
Question raised: A consultation is made regarding the taxation applicable to the taxpayer in Personal Income Tax for services rendered to the company.
Remuneration for the position of administrator constitutes income from employment pursuant to Article 17.2.e) of the Personal Income Tax Law (LIRPF). Income from services other than the position of administrator, as they do not meet the requirements for economic activities under Article 27.1, also constitutes income from employment. The valuation of these services must be carried out at their normal market value. The withholding tax rates provided for income from employment shall apply.
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