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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.
Question raised
Income from the provision of services is considered to be obtained in Spain when it is used within Spanish territory. In this case, the services of the doctors are used entirely in Spain to produce a work that is sent to a resident entity. The resident entity must apply withholding tax on the full amount of the sums paid, without applying deductions or reducing the base for social security charges.
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