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V1810-25 13 October 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Transport and hotel reimbursements in clinical trials may be taxable if not strictly compensating

A patient in a clinical trial asks whether mileage and hotel reimbursement is taxable under IRPF. The DGT states that, due to the absence of a labour relationship, the diet exemption does not apply, but considers the possibility of treating it as an expense incurred on behalf of a third party.

The question raised

Whether such amounts are subject to Personal Income Tax (IRPF).

The DGT's ruling

The tax exemption regime for per diems does not apply because there is no employment relationship. If the organizer directly provides means of transport and accommodation, there is no income. If the organizer reimburses expenses without proving they strictly compensate for travel, or pays amounts for free allocation, it is considered monetary income subject to Personal Income Tax (IRPF) and withholdings.

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