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A shareholder holding 33.33% of the capital and serving as an administrator consulted whether the exemption for income from work performed abroad could be applied. The DGT ruled that it is not applicable, as their status as both a shareholder and administrator suggests the absence of an employment relationship.
Cuestión planteada Si le es aplicable la exención prevista en la letra p) del artículo 7 de la Ley del Impuesto sobre la Renta de las Personas Físicas.
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