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An independent contractor from UNOPS asks whether their income is exempt under the UN Convention or the foreign work exemption. The DGT states that exemption under the Convention does not apply as they are not a UN official, and the foreign income tax exemption does not apply because the country of work is a tax haven.
Question posed: Whether the income received in the capacity of Project Manager for the UNOPS office is exempt from taxation in accordance with the Convention on the Privileges and Immunities of the United Nations.
The exemption under the United Nations Convention does not extend to independent contractors, but only to officials. On the other hand, the exemption under Article 7.p) of the Personal Income Tax Law (LIRPF) requires that the work be performed in a territory that is not considered a tax haven. As Saint Vincent and the Grenadines is a tax haven, said exemption cannot be applied.
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