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V1775-17 7 July 2017 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · residencia fiscal

Foreign work exemption requires services to be rendered to a non-resident entity or permanent establishment

A worker who resided in Germany and was seconded to Chile and Sweden by his Spanish company seeks advice on his tax residency and the application of the foreign work exemption. The DGT explains that the exemption applies if services are rendered to a non-resident entity or if they are intragroup services reporting profit to a foreign entity.

The question raised

Question raised 1) Tax residence of the taxpayer in the 2016 tax period.

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