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V1518-18 5 June 2018 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IVA · sujeción

Consultancy services for UNHCR are subject to but exempt from VAT and taxable under Personal Income Tax

A consultancy firm resident in Spain has requested clarification regarding the taxation of its services and expenses invoiced to UNHCR. The Directorate General for Taxes (DGT) has determined that the services are subject to but exempt from VAT, and that fees are taxable under Personal Income Tax (IRPF) as the individual is not a UN official.

The question raised

Question raised - Value Added Tax: liability of services invoiced to UNHCR and of economic compensations for travel.

The DGT's ruling

Consultancy services provided to international organizations such as UNHCR are subject to but exempt from VAT pursuant to Royal Decree 3485/2000. Reimbursements for travel and per diems form part of the taxable base for services that are subject and exempt. Regarding Personal Income Tax (IRPF), fees do not benefit from an exemption as the consultant is not a UN official, and travel expenses are deductible provided they comply with the principle of correlation with income and legal requirements.

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