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V2096-23 18 July 2023 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Manager remuneration and services considered as earnings from work

A consultant who will be the sole partner and manager of an electrical installations company asks how his services should be taxed. The DGT responds that payments for the managerial role are earnings from work, and that business services are also considered as such due to the lack of economic activity requirements.

The question raised

Question posed: A consultation is made regarding the taxation that will correspond to the taxpayer in Personal Income Tax for the services provided to the company.

The DGT's ruling

Remuneration for the position of administrator is considered income from employment pursuant to Article 17.2.e) of the Personal Income Tax Law (LIRPF). If the position is unpaid, no remuneration is imputed. Services other than administration, as they do not meet the requirements for economic activities under Article 27.1 of the LIRPF, must be considered income from employment. The valuation of these services must be carried out based on their normal market value.

Apply this to a real case

What is published here, applied to a company or a specific case. The first meeting is free.

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