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V2093-25 5 November 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · residencia fiscal

Cannot determine if OECD salary is tax-exempt due to lack of specific information

An OECD officer resident in Spain asks whether their salary is exempt from IRPF under the organisation's privileges and immunities. The DGT states that while tax exemptions may apply, the information provided is too general to address the query.

The question raised

Whether the salary received from the OECD should be excluded from their worldwide income to be declared in the Personal Income Tax (IRPF) in Spain through the application of the OECD foundational agreements on privileges and immunities (Article 14.b of Protocol No. 1).

The DGT's ruling

Tax residents in Spain are taxed on their worldwide income, except for legal exemptions or international treaties. Additional Protocol No. 1 to the European Economic Cooperation Convention establishes that OECD officials enjoy the same tax exemptions as personnel of major international organizations. However, because the information provided is too generic, the DGT cannot provide an answer to the question asked.

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