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V1677-23 13 June 2023 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Administrator remuneration classified as income from work

The DGT states that payments for administrative roles are income from work, while professional services may be classified as income from economic activities if certain conditions are met.

The question raised

Classification under Personal Income Tax (IRPF) of the remuneration received by the company director for the provision of services to the company.

The DGT's ruling

Remuneration for director functions constitutes income from employment pursuant to Article 17.2 of the Personal Income Tax Law (LIRPF). Services provided outside the scope of administration may constitute income from economic activity if the company provides professional services (Section Two of the Economic Activities Tax Index (IAE)), the partner performs tasks inherent to that corporate purpose, and is registered in the self-employed regime or a mutual fund. Otherwise, they are considered income from employment.

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