Skip to content
Back to index
V2135-15 13 July 2015 · SG de Fiscalidad Internacional Criterion in force
IRNR · residencia fiscal

Earnings from work in Spain are taxed in Spain regardless of worker's residence in Portugal

A worker moving to Portugal seeks advice on their tax residency and the taxation of Spanish-source income. The DGT states that if Portuguese residency is proven, income from work carried out in Spain is taxed in Spain via IRNR.

The question raised

The taxpayer raises the following questions in relation to the years 2015, 2016, and 2017:

The DGT's ruling

If the taxpayer proves their residence in Portugal, Spain shall only tax income from Spanish sources in accordance with the TRLIRNR and the Convention. Income from employment exercised in Spain is taxed in Spain; dividends are limited to 15% by the Convention; interest on deposits is exempt; capital gains from the sale of shares are generally taxed only in Portugal; and income from real estate in Spain is taxed in Spain.

Book your free first meeting