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The DGT confirms that payments to non-resident doctors for technical opinions in medical consensus work are subject to Spanish IRNR, with retention applied on the full invoice amount.
Cuestión planteada
Las rentas por prestaciones de servicios se consideran obtenidas en España cuando sean utilizadas en territorio español. En este caso, los servicios de los médicos se utilizan íntegramente en España para confeccionar un trabajo que se remite a una entidad residente. La entidad residente debe practicar la retención sobre el importe íntegro de las cantidades pagadas, sin aplicar deducciones ni minorar la base por cargas sociales.
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