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A company inquired whether payments to student orchestras were indemnity payments and whether payments to a coordinator constituted business benefits. The DGT clarifies that artists' earnings and related expenses are taxable in Spain and that retention must be applied on the full amount paid.
Cuestión planteada
Las rentas de artistas, incluyendo ensayos y gastos de viaje o manutención, pueden someterse a imposición en España según el Modelo de Convenio de la OCDE. La retención debe practicarse sobre el importe íntegro de la renta bruta satisfecha, sin deducir los gastos vinculados a la actividad. Los pagos al coordinador por servicios de organización se consideran beneficios empresariales y tributan en su país de residencia, salvo establecimiento permanente en España.
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