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V1430-15 8 May 2015 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · exención por trabajos en el extranjero

Exemption not applicable for foreign work performed for a Spanish company

A worker temporarily deployed to Morocco by a Spanish company asks whether exemption for foreign work applies. The DGT responds that it does not, as the work is carried out for a Spanish resident entity.

The question raised

Question posed: Application of the exemption established in letter p) of Article 7 of the Personal Income Tax Law.

The DGT's ruling

To apply the exemption under Article 7(p) of the Personal Income Tax Law (LIRPF), the work must be performed for a non-resident company or a permanent establishment abroad. In this case, as the work is performed for a Spanish company, the requirement that the recipient entity be a non-resident is not met. Therefore, the exemption for work performed abroad is not applicable.

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