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V1613-14 23 June 2014 · SG de Fiscalidad Internacional Criterion in force
IRPF · residencia fiscal

Swiss bonus taxation depends on beneficiary's Spanish tax residency

A Spanish national resident in Switzerland asks how a bonus paid by a Swiss company via a Luxembourg transfer to a Spanish account is taxed. The DGT explains that the payment's origin does not affect taxation, and fiscal treatment depends on whether the recipient is a Spanish resident or not.

The question raised

The manner in which this receipt of funds is taxed in Spain.

The DGT's ruling

If the inquirer is a non-resident, they shall only be taxed in Spain on employment income earned within Spanish territory. If they are a tax resident in Spain, they shall be taxed on their worldwide income, which may also be taxed in Switzerland pursuant to the Double Taxation Convention. The fact that the transfer is made from Luxembourg to an account in Spain has no tax implications.

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