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V1999-15 26 June 2015 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · atribución de rentas

Remuneration of a partner for work performed in a civil society is considered income from economic activity

The taxpayer asks whether remuneration for work performed in a physiotherapy civil society should be taxed as income from employment. The DGT responds that, due to the income attribution regime, these amounts constitute part of the income from the economic activity attributable to the partner.

The question raised

Question posed: Application to the remuneration received by the taxpayer for work performed through the civil society, of the third paragraph of section 1 of Article 27 of the Personal Income Tax Law.

The DGT's ruling

Income received by a partner for work performed in an entity under the income attribution regime does not constitute income from employment, but rather a portion of the income from the economic activity of the entity attributable to them. This implies a greater participation of the partner in the net income of the company. Consequently, these amounts do not constitute a deductible expense for the entity.

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